Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Website and tells You about Your privacy rights and how the law protects You. By using the Website, You agree to the collection and use of information in accordance with this Privacy Policy.

I. Interpretation and Definitions

A. Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

B. Definitions

“Account” means a unique account created for You to access our Website or parts of our Website.

“Affiliate” means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.

“Company” (referred to as either “the Company”, “We”, “Us,” or “Our” in this Agreement) refers to Sustainable Capital Advisors, LLC d/b/a AskSustainable, 1875 K St. NW Fourth Floor Washington, DC 20006. For the purpose of the GDPR, the Company is the Data Controller.

“Cookies” are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

“Data Controller,” for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

“Device” means any device that can access the Website such as a computer, a cell phone or a digital tablet.

“Do Not Track (DNT)” is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites. Our Website does not respond to Do Not Track signals.

“Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

“Sale,” for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

“Website Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website, to provide the Website on behalf of the Company, to perform services related to the Website, or to assist the Company in analyzing how the Website is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

“Usage Data” refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

“Website” refers to AskSustainable, accessible from http://www.asksustainable.com

“You” means the individual accessing or using the Website, or the company or other legal entity on behalf of which such individual is accessing or using the Website, as applicable.

II. Collecting and Using Your Personal Data

A. Types of Data Collected

1. Personal Data: While using Our Website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: (1) email address; (2) first name and last name; and (3) Usage Data.
2. Usage Data: Usage data is collected automatically when using the Website through any Device. Usage Data may include information such as Your Device’s Internet Protocol (IP) address, browser type, browser version, operating system, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique Device identifiers, and other diagnostic data.

B. Tracking Technologies and Cookies: We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website. The technologies We use may include:

1. Cookies or Browser Cookies. A Cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. Our Website may use Cookies and if You do not accept Cookies, You may not be able to use some parts of our Website.

2. Flash Cookies. Certain features of our Website may use local stored objects (or flash Cookies) to collect and store information about Your preferences or Your activity on our Website. Flash Cookies are not managed by the same browser settings as those used for browser Cookies.

3. Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

III. Use of Your Personal Data

A. The Company may use Personal Data for the following purposes:

1. To provide and maintain our Website, including to monitor the usage of our Website.

2. To manage Your registration as a user of the Website. The Personal Data You provide can give You access to different functionalities of the Website that are available to You as a registered user.

3. To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.

4. To provide You with news, special offers and general information about other goods, services, and events which we offer unless You have opted not to receive such information.

5. To attend and manage Your requests to Us.

6. We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other Sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Website users is among the assets transferred.

7. We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Website, products, services, marketing, and your experience.

B. We may share Your personal information in the following situations:

1. We may share Your personal information with Service Providers to monitor and analyze the use of our Website or to contact You.

2. We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

3. We may share Your information with Our Affiliates. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.

4. We may share Your information with Our business partners to offer You certain products, services, or promotions.

5. When You share personal information or otherwise interact in the public areas of the Website with other users, such information may be viewed by all users and may be publicly distributed outside of the Website.

6. We may disclose Your personal information for any other purpose with Your consent.

IV. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.

V. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

VI. Disclosure of Your Personal Data

A. Business Transactions: If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

B. Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

C. Other legal requirements: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: (1) comply with a legal obligation; (2) protect and defend the rights or property of the Company; (3) prevent or investigate possible wrongdoing in connection with the Website; (4) protect the personal safety of Users of the Website or the public; (5) protect against legal liability.

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VII. Third-Party Processing: The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Website in accordance with their Privacy Policies.

A. Analytics: We may use third-party Website providers to monitor and analyze the use of our Website.

1. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

B. Usage, Performance and Miscellaneous: We may use third-party Service Providers to provide better improvement of our Website.

1. We use NextAuth for authentication services. The NextAuth service may collect information from You and from Your Device for security purposes.

VIII. Your California Privacy Rights

California’s “Shine the Light” law permits California residents to request certain information regarding Our disclosure of information to third parties for their direct marketing purposes. We share Personal Information with third parties for their direct marketing purposes. California residents may obtain information about Our compliance with this law by sending an e-mail to hello@asksustainable.com. Requests must include “California Privacy Rights Request” in the first line of the description and include Your name, street address, city, state, and ZIP code. Please note that We are not required to respond to requests made by means other than through the provided e-mail address or mail address.

IX. Your European Privacy Rights

A. Data Controller: Data protection laws in Europe make a distinction between organizations that process personal data for their own purposes (“Controllers”) and organizations that process personal data on behalf of other organizations (“Processors”). We generally act as the controller of your information submitted to Us through Our Website.

B. Lawful Basis for Processing: Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) You have given Your consent to Our processing for a specific purpose, either to Us or to Our service providers or partners; (b) processing is necessary to comply with a legal obligation; or (c) processing is necessary for the purposes of the legitimate interests pursued by Us and fundamental rights do not override these interests.

C. Data Subjects’ Rights: If you are a data subject in Europe, You have the right to access, rectify, or erase any personal data We have collected about you through the Website. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Website. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

D. You may exercise your rights by submitting a written request to us at the address set forth in the “Contact Us” section. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

X. Governing Law and Jurisdiction

A. All matters relating to the Website and this Privacy Policy, and any dispute or

claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the District of Columbia without giving effect to any choice or conflict of law provision or rule.

B. Any legal suit, action, or proceeding arising out of, or related to, this Privacy Policy or the Website shall be instituted exclusively in the District of Columbia, although We retain the right to bring any suit, action, or proceeding against You for breach of these Terms in Your country of residence or any other relevant country. You waive any and all objections to the exercise of jurisdiction over You by such courts and to venue in such courts.

C. At Company’s sole discretion, it may require You to submit any disputes arising from this Privacy Policy or use of the Website, including disputes arising from or concerning their interpretation, violation, invalidity, non-performance, or termination, to final and binding arbitration under the Rules of JAMS applying the law of the District of Columbia.

XI. Waiver and Severability

A. No waiver by the Company of any term or condition set out in this Privacy Policy shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure of the Company to assert a right or provision under these Terms shall not constitute a waiver of such right or provision.

B. If any provision of this Privacy Policy is held by a court or other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent such that the remaining provisions of these Terms will continue in full force and effect.

XII. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: hello@asksustainable.com

By phone number: +1 844.787.8227

By mail: 1875 K St. NW Fourth Floor Washington, DC 20006