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Legal Document · Version 260101

Privacy Policy

G4Green – Privacy Policy

Version: 260101

This Privacy Policy describes how ImpactGulf (“we”, “us”, “our”) collects, uses, discloses, and protects personal data when you access or use the G4Green platform (“G4Green”, “Platform”, “Service”). We are committed to protecting your privacy and processing personal data in a transparent and lawful manner.

1. Scope of This Privacy Policy

This Privacy Policy applies to:

  • Registered users of G4Green (corporate, public-sector, NGO, and membership-based organisations)
  • Visitors who browse publicly available content on the Platform
  • Users of optional services such as Impact Lab

This Policy does not apply to third-party websites or services linked from G4Green.

2. Data Controller

The data controller responsible for your personal data is:

ImpactGulf

Masdar City, Abu Dhabi, United Arab Emirates

Email: [email protected]

3. Types of Personal Data We Collect

We may collect the following categories of personal data:

3.1 Account and Contact Information:

  • Name
  • Business email address
  • Job title and organisation
  • Contact details
  • Account credentials

3.2 Platform Usage and Technical Data:

  • Log files and usage data
  • IP address
  • Browser type and device information
  • Date and time of access

3.3 Sustainability-Related Data:

  • Information submitted in connection with Green Ratings and Green KPIs
  • Verification documentation (where applicable)
  • Public profile data (only if publication is enabled)

3.4 Communications:

  • Support requests
  • Email correspondence
  • Feedback and enquiries

3.5 Impact Lab Services:

Where Impact Lab services are used, additional data may be processed under separate scopes of work, limited to what is necessary for service delivery.

4. Purposes and Legal Bases for Processing

We process personal data for the following purposes:

PurposeLegal Basis
Platform access and account managementContractual necessity
Sustainability performance trackingLegitimate interest / Contract
Verification and fraud preventionLegitimate interest
Optional public display of sustainability dataConsent
Provision of Impact Lab servicesContract
Platform security and improvementLegitimate interest
Legal and regulatory complianceLegal obligation
Coordination of platform-led sustainability initiatives and assignment and management of platform Green KPIs by G4Green in its role as Platform Green LeaderLegitimate interest / Contract
Facilitating the assignment, participation, and tracking of Green KPIs defined by external Green Leaders, based on the relationship between Green Leaders and participating Green StarsContract or Legitimate Interest, depending on setup

5. Public Visibility and User Controls

  • Basic users: Green Ratings are for internal use only.
  • Premium users: May choose to display Green Stars and sustainability tiers on Green Connect.
  • Public visibility is optional and can be enabled or disabled at any time.

We do not publish personal data without a valid legal basis.

Public visibility of data related to KPIs assigned by external Green Leaders is governed by the visibility settings selected by the participating Green Star and the applicable programme rules defined by the Green Leader.

Where G4Green coordinates platform-led sustainability initiatives or Green KPIs in its role as Platform Green Leader, participation preferences (including opt-in or opt-out of optional initiatives) are processed for platform governance and functionality purposes only. Any public communication or reporting related to such initiatives is aggregated and non-comparative unless a user explicitly consents to individual disclosure.

6. Impact Tokens and Green KPIs

Personal data processed in connection with Green KPIs, Impact Tokens, and Verification activities is limited to what is strictly necessary to ensure integrity, transparency, and credibility of sustainability engagement.

Impact Tokens are not a currency, not a financial instrument, and not transferable outside the Platform.

Personal data processed in connection with platform-led Green KPIs coordinated by G4Green as Platform Green Leader is limited to what is necessary to manage participation, measure completion, distribute incentives where applicable, and ensure platform integrity.

6.1 Platform Participation Logic

G4Green may process limited account-level preference data to determine a user's eligibility and participation in optional platform-led Green KPIs and sustainability initiatives. Such processing does not involve automated decision-making that produces legal or similarly significant effects on users.

7. Use of Distributed Ledger Technology (Blockchain)

G4Green uses distributed ledger technology (blockchain) as part of its technical infrastructure to ensure integrity and traceability of certain platform records, such as Impact Token issuance and verified sustainability actions.

  • We do not store directly identifiable personal data on the blockchain.
  • Any references recorded on-chain are pseudonymised, hashed, or non-personal.
  • Personal data remains stored off-chain in controlled environments.

Due to the technical nature of blockchain, on-chain records may be immutable and irreversible. Your data protection rights apply fully to personal data processed off-chain.

8. Data Sharing and Disclosure

We may share personal data with:

  • Trusted service providers (hosting, security, analytics)
  • Verification partners (where applicable)
  • Professional advisers (legal, audit)
  • Authorities where legally required

All third parties are contractually bound to protect personal data and use it only for authorised purposes. We do not sell personal data.

Aggregated and anonymised data derived from platform-led sustainability initiatives may be used for reporting, communication, or research purposes. Such data does not identify individual users unless explicit consent has been provided.

Where Green KPIs are assigned by external Green Leaders, relevant sustainability-related data may be shared with the assigning Green Leader in accordance with platform settings and the relationship between the parties. G4Green does not share personal data beyond what is necessary to enable such participation.

9. International Data Transfers

Personal data may be processed in jurisdictions outside your country of residence. Where required, we implement appropriate safeguards, including: Contractual protections; Adequacy decisions; Technical and organisational measures.

10. Data Retention

We retain personal data only for as long as necessary to: Provide the Platform; Meet contractual obligations; Comply with legal requirements.

Where data is no longer required, it is securely deleted or anonymised, except where technical limitations (e.g. blockchain immutability) apply.

11. Your Rights

Subject to applicable law, you may have the right to: Access your personal data; Rectify inaccurate data; Request erasure of personal data; Restrict or object to processing; Withdraw consent (where applicable); Lodge a complaint with a supervisory authority.

Requests can be submitted to: [email protected]

Where processing is based on legitimate interest related to platform governance or functionality, users may object to such processing in accordance with applicable law.

12. Security Measures

We implement appropriate technical and organisational measures to protect personal data against: Unauthorised access; Loss or misuse; Alteration or disclosure.

No system is completely secure, but we continuously improve our safeguards.

13. Children's Privacy

G4Green is a B2B and institutional platform and is not intended for use by children. We do not knowingly collect personal data from minors.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updated versions will be published on the Platform with a revised date. Continued use of G4Green constitutes acceptance of the updated Policy.

15. Contact

If you have questions or concerns regarding this Privacy Policy, please contact:

ImpactGulf

Email: [email protected]

Questions about this document? [email protected]

ImpactGulf Limited · Masdar City, Abu Dhabi · P.O. Box 35080, Dubai, UAE