Privacy Policy

Last updated on June 1, 2024

Welcome to Tese! Tese provides small and medium enterprises with a suite of tools intended to help them monitor and improve their ESG metrics.

https://tese.io (the“Website”) is operated by Tese Capital Limited. Throughout this privacy policy (the “Privacy Policy”), the terms “Tese”, “we”, “us” and “our” refer to Tese Capital Limited. This Privacy Policy applies to the Website and Tese’s services as further described in our Terms of Use here, together referred to as the “Services”.

Tese is the controller of your personal information, and is responsible for the collection, processing and disclosure of your personal information as described in thisPrivacy Policy, unless expressly specified otherwise. If you have any questions about this Privacy Policy or want to exercise your rights hereunder, please write to us at support@tese.io.

Tese is committed to protecting and respecting your privacy, and will only use any personal information submitted in conformity with all applicable laws and regulations, and in accordance with this Privacy Policy.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on our Website. If we make material changes to this Privacy Policy, we will notify you that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

By continuing to use our Services, you agree to the revised Privacy Policy to the fullest extent permitted by applicable law.

1. Processing Activities Covered

This Privacy Policy applies to any and all personal information provided by you to Tese, and without limiting the generality of the foregoing, the following processing activities:

-       Visiting and accessing our Website, which displays or links through to this PrivacyPolicy;

-       Signing up or having an account created to become a user/subscriber;

-       Requesting, using, purchasing and/or subscribing to, as applicable, anyof our Services;

-       Communicating with us to report a problem or to submit queries, concerns or comments regarding the Services;

-       Communicating with us via our Website, email, social media, Tese’s AI Chatbot, text message and/or phone call.

This Privacy Policy does not apply to processing activities where we are not the controller.

2. Personal Information We Collect

We only collect the personal information that is necessary to carry out our business, provide the Services you requested and keep you informed of the latest news about us.

Subject to certain exceptions and limitations, personal information is any information which relates to a natural person and directly or indirectly allows that person to be identified.

The personal information that we collect directly from you may include the following:

-       Personal identifiers, which may include, without limitation, your email address, name, gender, ethnicity, job title, employer information, address (residential and professional), telephone number (residential and professional), fax number (residential and professional), signature.

-       Banking information;

-       Commercial information, which may include your billing information and purchase history;

-       Internet or other electronic network activity information, which may include, without limitation, browsing history, search history, and information regarding interaction with an internet website, application or advertisement;

-       Geolocation data, which may include, without limitation, current and historical physical location including the country, state, city, zip code, address and/or location over time; and 

-       Inferences we make, which may include your likelihood of retention.

3. Personal Information of Children

The Services are not intended for use by children under the age of 18.  

However, we understand the importance of protecting children’s privacy online. If we learn that we have collected personal information from someone under the age of 18, we will delete that information as quickly as possible. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us, and we will promptly respond.

4. Device and Usage Date

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain personal information, from your computer or mobile device as you navigate our Website or interact with emails we have sent to you.

As is true of most websites, we gather certain information automatically via log files. This collected information may include yourInternet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet serviceprovider and/or mobile carrier, the pages and files you viewed, your searches,your operating system and system configuration information, and date/timestamps associated with your usage.

This information is used to comply with data contracts, treaties, national laws, and regulations, analyze overall trends to help us provide and improve our Services, and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Services’ security features. 

We use cookies and similar technologies such as web beacons, tags, and Javascript alone or in conjunction with cookies to compile information about usage of our Services, and interaction with emails from us.

When you visit our Website or otherwise access any of our Services, our servers or an authorized third party may place a cookie on your browser, which can collect information, including personal information, about your online activities over time and across different sites.Cookies help us ensure our Services are not misused by bots and prevent account login information sharing.

We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer or device. Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set by using the opt-out tool at https://optout.networkadvertising.org/.You can also learn more about cookies by visiting https://allaboutcookies.org/ which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used by us, you may not be able to take full advantage of the Services. We partner with a third-party ad network to either display advertising on our Services or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities with regard to the Services and other websites to provide you targeted advertising based upon your interests, which is called online behavioural advertising. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using the specificopt-out mechanism at https://optout.networkadvertising.org/.Please note this doesnot opt you out of being served advertising. You will continue to receive generic ads.

Some Internet browsers may be configured to send "Do Not Track" signals to theonline services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, Tese does not currently alter our practices when we receive a "Do Not Track" signal from a visitor’s browser except as specifically required by law. For information about "do nottrack" from The Future of Privacy Forum, click here.

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5. Third Parties and Social Media Features

Third parties with whom we work may also provide us with information about you. We may combine the information you have given to us with additional information made available by external sources. For example, depending on your settings or the privacy policies for social media and messaging services like Facebook or Instagram, you may give us permission to access information from those accounts or services. Please verify theprivacy policies of these third parties before submitting your personalinformation to them.

Conversely, Tese may use social media features, such as the Facebook and Instagram “like” button and other sharing widgets (“SocialMedia Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our Website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our website with your social media profile. Your interactions with Social MediaFeatures are governed by the privacy policies of the companies providing the relevant Social Media Features.

This Privacy Policy only addresses the collection, use and disclosure of personal information by Tese. The third parties that provide other websites or services that may be accessible through Tese’s Services may have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion

6. Purposes and Legal Basis

We collect and process your personal information for the purposes and on the legal basis identified below:

-      Administering our Services and performing contracts: We use your personalinformation to enable us to operate and administer our Services, and to perform any contract with youaccording to any applicable terms of service;

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-       Managing user registrations: Wewill process your personal information by managing your user account for thepurpose of performing the contract with you according to any applicable termsof service, and relevant national laws and regulations;

-      Handling contact and user support requests: If you contact us by any available means, we will process your personal information to the extent it is necessary to fulfill your request and communicate with you;

-      Developing and improving our Services: We will process your personal information to analyze trends and track your usage of our Services, and interactions with emails to the extent this is necessary for us to develop andimprove our Services, conduct market research, and provide our users with more relevant content;  

-       Sending communications: We will process your personal information to send you the latest updates about us, including information about our Services, to the extent you have provided your prior separate consent;

-      Complying with legal obligations: We will process your personal information when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws tot he extent this requires the processing or disclosure of personal information to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of data hosted on our Website, our data, our Services, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court order, or legal process, and/or to respond to lawful requests.

Where we need to collect and process personal information by law, or under a contract we have entered into with you and you fail to provide that required personal information when requested, we may not be able to perform the contract.

Where your personal information is anonymized or de-identified, we do not require a legal basis to use it as the information will no longer constitute personal information under the applicable data protection law. Our use of anonymized or de-identified data is not subject to this Privacy Policy.

7. Sharing Personal Information with Third Parties

As part of our Services, we may share the personal information you provide to us, with various vendors, content creators, educational institutions, financial institutions, NGOs and/or other third parties as directed and authorized by you when using our Services. This Privacy Policy does not address how such these third parties will use and disclose information obtained using our Services. TESE SPECIFICALLY DISCLAIMS ANY AND ALL LIABILITY IN CONNECTION WITH ANY THIRD PARTY’S USE OF YOUR PERSONAL INFORMATION OR PERSONAL INFORMATION SUBMITTED BY YOU. IT IS EACH THIRD PARTY’S RESPONSIBILITY TO USE AND DISCLOSE ALL PERSONAL INFORMATION IN ACCORDANCE WITH APPLICABLE LAWS AND REGULATIONS.

We may transfer personal information to non-affiliated service providers such as IT and system administration and hosting, research and analytics, marketing, account management, technical operations, credit card processing and email service providers to send out emails on our behalf, pursuant to agreements that prohibit the service providers from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information. Our contracted service providers’ addresses and contact information are reproduced below:

We may disclose aggregate statistics about our users in order to describe our business to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information. We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing our services, processing transactions, receiving and sending communications, updating marketing lists, analyzing data, providing IT and other support services, or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions. In the event of a sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Privacy Policy.

We reserve the right to disclose your personal information as required by law, and as necessary to protect the property, interests and rights of Tese.

In individual cases, we may also share personal information with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance, and accounting services.

8. Retention of Personal Information

We will keep your personal information only as long as is reasonably necessary for the time consistent with the original purpose of collection or such longer period as may be required by applicable law. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of your personal information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means. Personal information that is no longer required to fulfil the identified purposes will be promptly and securely destroyed, erased, or made anonymous.

9. Your Access and Control Over Your Personal Information

You may exercise any of the rights described below by contacting us at support@tese.io or by using the contact information indicated in this section. Please note that we may ask you to verify your identity before taking further action on your request. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question answer and other information. We will process your request within thirty (30) days of receipt.

a) Managing Your Information

You are responsible for keeping your personal information up-to-date. You can also ask us to correct inaccurate or incomplete personal information concerning you that you cannot update yourself.

b) Access to Your Information

You have the right to request information about the personal information we hold on you at any time. You can contact us at support@tese.io and we will provide you with your personal information via email. If you require additional copies, we may need to charge a reasonable fee.

If you are a Californian resident, once per calendar year, you may request that we provide a list of companies to which we disclose your personal information for business purposes, and a list of the categories of such personal information that we share. You may request further information about our compliance with this law by contacting us. Please include “California Privacy Rights Request” in the first line of the description and your California mailing or street address. Please note that we are only required to respond to one request per client each year, and we are not required to respond to requests made by any other means, nor to requests made by non-California US residents.

c) Right to Erasure

If you no longer want us to use your information to provide you with the latest news about our services and/or other helpful information, you can request that we erase your personal information by contacting us at support@tese.io.

Please note, however, that we may retain some of your personal information as necessary for our legitimate interests, such as fraud detection and enhancing security. We may also retain and use your personal information to the extent necessary to comply with our legal obligations, such as keeping information for tax, legal reporting and auditing obligations, as well as professional obligations. Information you have shared with others (e.g. comments, community postings) may continue to be publicly visible. Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers. Residual copies may also be kept in our backup systems. If we have shared your personal information with our service providers, we will let them know about the erasure where possible.

d) Right to Object to Direct Marketing

If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. If you have already given your consent but you prefer not to receive promotional information from us, you may unsubscribe by using the unsubscribe link situated at the bottom of any promotional message you receive from us, or by contacting us at support@tese.io

To the best of its knowledge, Tese is in material compliance with applicable anti-spam laws.

Hong Kong – Direct marketing

The following provisions apply if you are a user in Hong Kong.

If we intend to use your personal information in direct marketing, we will do so if you have given us your consent (or an indication of no objection, if your personal information is obtained in Hong Kong).

We may use your personal information (including your name and contact details) to send you marketing communications and promotional offers (including conducting promotional activities and operating membership loyalty schemes) in relation to the Services and other services and products from Tese, our affiliate companies, and third parties contracted with Tese.  Such products, services and activities may be offered/provided by us or any of our affiliate companies or contracted vendors.

In addition, we may also use your personal information to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to you or others.

We may provide your personal information to our affiliate companies for their use in conducting the activities referenced in this "Hong Kong – Direct marketing" section.

You may opt-out of receiving direct marketing communications from us at any time, free of charge, by: (a) following the opt-out instructions contained in our marketing communications; or (b) contacting us at support@tese.io.

e) Restriction of Processing

You can ask us to block or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it and we have no legitimate grounds that override yours. Such request alone does not stop us from storing your personal information.

If you are a Californian resident, you have the right to opt-out of the sale of your personal information. Under the California Consumer Privacy Act (the “CCPA”), the “sale” of personal information broadly includes any communication of personal information to any business that is deemed to be a “third party” (as defined in the CCPA) for monetary or other valuable consideration, subject to certain exceptions and limitations.  If you would like to submit such a request, please send your request to support@tese.io.

f) Right to Portability

Whenever we process your personal information, by automated means based on your consent or based on an agreement, you have the right to get a copy of your personal information transferred to you or to another party. This only includes the personal information you have provided to us.

g) Automated Decision-Making

You have the right to elect not to be subject to a decision based solely on automated processing, including profiling, without any human involvement ("Automated Decision-Making"). Our Services currently use Automated Decision-Making to make customized purchase recommendations for products and services to you based on your sustainability data collected by or submitted to Tese. Sustainability data includes any and all information that relates to any activity or operation conducted by a company with environmental, social, or corporate governance impacts, and may include personal information. If you elect not to be subject to this Automated Decision-Making, you will not be able to receive such customized recommendations. You will continue to receive generic recommendations. Please send your request to support@tese.io.

h) Consent Withdrawal

To the extent we base the collection, processing, and sharing of your personal information on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

i) Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

j) Right to Limit the Use of Sensitive Personal Information

If you are a resident of a jurisdiction with laws that provide for a right to limit the use of sensitive personal information, as defined in the applicable law(s), you have the right to limit the use of your sensitive personal information to only those purposes that are necessary for us to provide the Services to you, by contacting us.

j) Authorized agent

If you are a Californian resident, you may use an authorized agent to exercise certain privacy-related requests and rights on your behalf.  The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose.  If your authorized agent submits the exercise or request online, a copy of the power of attorney or the original notarized statement shall be sent to us by mail.

k) Questions or Complaints

If you have any queries or would like to make any complaint in relation to this Privacy Policy and our privacy practices, you may contact us at support@tese.io or at the following address:

TESE INC.
PRIVACY OFFICER

If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the competent supervisory authority.

10. Personal Information Security

We take reasonable precautions to ensure the protection of personal information collected, used or disclosed by us using appropriate physical, organizational and technological measures. We use industry-standard encryption technologies to receive sensitive data submitted by you via our Services. For more information regarding Tese’s security safeguards

In case of a breach of personal information that is likely to result in a high risk to your rights and freedoms, we will notify you and the proper authority as soon as feasible following becoming aware of the breach and without undue delay.

While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. If you have any questions about the security of our Services please contact us using the contact information in the “Questions or Complaints” section above.

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