Privacy Policy – ZeroMe Mobile App

The ZeroMe program (the “Program”) is a voluntary sustainable living program that encourages sustainable choices. The Program is paid for by your employer or other sponsoring organization (the “Program Sponsor”) and operated by BreakthroughFuel LLC, a limited liability company organized under the laws of the State of Wisconsin, headquartered at 1175 Lombardi Avenue, Green Bay, WI 54304 (“BTF,” “we,” “us,” or “our”).

We are committed to protecting your privacy and the personal information you share with us through your use of the App. This Privacy Policy describes the types of personal information we collect about you through the App and how we use that information. This Privacy Policy applies specifically to use of the ZeroMe mobile application (the “App”) and does not apply to any other data, including data that we collect through other platforms (e.g., our websites) or offline. Information about our privacy practices for data obtained through these other sources can be found here.

We have designed this Privacy Policy in a question and answer format to make it easy to read and understand. Please read through it carefully. If you do not agree with our policies and practices contained in this Privacy Policy, please do not enroll in the Program.

What information does BTF collect about me?

We collect both anonymous and Personal Information about you to provide you with the Program and related services. “Personal Information” means any information, including personal and material circumstances, that allows a person to become identifiable. The Personal Information we collect includes, but is not limited to:

Your contact information, including your first name and last name, home postal code, country, employer name, employer division, and business email addresses
The email address you use to sign-in and receive information regarding your purchases, if any • Your profile information
Information about your participation in the Program; and Information you voluntarily share about yourself through calls, queries or requests to our application support services or otherwise voluntarily share with us.

Please keep in mind that the extent of the Personal Information you may be able to share with us will depend on the Program design and the features made available to you by the Program Sponsor, as well as your level of participation in the Program. You are under no obligation to provide any Personal Information to us at any time. However, if you choose to withhold some Personal Information, we may be unable to provide you with certain services.

How does BTF use my Personal Information?

We will use the Personal Information collected only to provide you with access to the Program, including:

To administer and manage the Program and related services, including the App; • To administer and manage your Program account and participation;
To identify you when you enroll or sign-in;
To track your progress in the Program;
To provide you with information about the Program and Program features; • To respond to your questions and requests; and
To provide appropriate security and confidentiality controls to protect your Personal Information.

Additionally, we may create “Anonymous Data” records by removing any Personal Information (including any contact information) that would allow the remaining data to be linked back to you and aggregating it with other Anonymous Data. We may use the Anonymous Data for internal purposes, such as analyzing patterns and Program usage to improve our services. Additionally, we may use Anonymous Data to analyze and understand customer behavior patterns and preferences, and information that can help us enrich the content and quality of the Program.

How will BTF communicate with me?

If you have opted to receive push notifications on your mobile device, we may, from time to time, send you push notifications to provide you with reminders and notices. If you no longer wish to receive such communications, you may turn them off at the device level.

From time to time, we may send you e-mails or newsletters with information about your Program, any available features, or related services.You may opt-out of our communications, free of charge, at any time by deleting your account.

Can BTF contact me directly by phone?

No, we do not collect your phone number(s).

How does BTF collect my Personal Information?

We collect Personal Information you voluntarily provide as you submit it through the App (for example by answering sustainability questions), by reviewing your use of the App (for example through the completion of surveys or assessments), and when you participate in related services or events. Depending on the Program design selected by your Program Sponsor, we may collect Personal Information through your use of additional services. We may also collect information about you and your participation in the Program through engagement surveys. Depending on your Program design, your Program Sponsor may have the opportunity to create surveys for its sponsored users to complete.

We may also automatically collect additional information from the App, including the referring and exit pages, the files viewed (e.g., HTML pages, graphics, etc.), date and time stamps of activity, the accessing IP address (the unique address that identifies your device on the internet) and the operating system your device uses. We use this additional information to derive a broad, non-specific understanding of the locations from which users access the App, and to enhance the security controls around platform access. We also use it to analyze trends, administer the platform, and track users’ movements on.

What information do surveys collect from me?

As part of the Program, you will be asked to provide answers to questions related to your habits to analyze carbon emissions. You may choose not to answer any question(s). If you decide to provide responses, the results will be provided to your Program Sponsor in aggregate reports. Your Program

Sponsor will not be able to identify you from the report, unless you choose to provide any Personal Information in an open-ended written response.

Does BTF collect Personal Information about children?

As explained in the Terms of Service, the Program is designed for adults over the age of 18, but minors as young as 16 may participate in the Program under the supervision of a responsible adult. We do not knowingly collect Personal Information about children under the age of 13. If you have reason to believe that we have inadvertently collected Personal Information about anyone under the age of 13, please contact us to remove the Personal Information.

Does BTF receive information about me from other sources?

Yes. We may receive information about you from various sources to support the Program and services included with it. The sources may include:

Your Program Sponsor
Depending on your Program design, your Program Sponsor may provide us your Personal Information to identify you as an individual who is able to join the Program. We call this an “Eligibility File”. Please contact your Program Sponsor directly if you wish for your Program Sponsor to stop sending us information about you. Keep in mind that if you are removed from the Eligibility File you will no longer have access to the Program and will not be able to enroll in the Program.

ZeroMe Program Partners
Depending on your Program design, you may have access to organizations through our Program that partner with us to provide some services. If you use these services, the Program Partners may share activity information and results with us. This data sharing would be limited to information necessary to support your goals or participation in the Program.

What tools does BTF use to collect my Personal Information?

ZeroMe, its Program Partners and vendors use tools such as Cookies, tags, scripts and other similar technologies to enhance and support your experience on the platform. These technologies help us administer the mobile application, measure traffic patterns and the total number of users, as well as to personalize and customize the platform’s content, so that your settings are “remembered” when you login.

Does BTF use mobile analytics?

We use mobile analytics software to allow us to review the functionality of our mobile software on your phone, and how to improve its quality and our services. The mobile analytics software may record information such as how often you use the mobile application, the events that occur within the mobile application, crash reports and performance data, where the application was downloaded from and other metrics, such as aggregated usage. The information collected by the mobile analytics software is managed separately from other Personal Information you submit within the mobile application.

Are there links to third party websites and mobile applications on the App?

The App may contain links to other websites that we do not own or control. We provide these links and connections for your convenience. We have no control over these third parties, their privacy policies, and the content they display on their websites or mobile applications. If you choose to submit Personal Information while visiting these websites or using these mobile applications, please be aware your rights will be governed by the third parties’ privacy policies. We strongly encourage you to carefully read the privacy notice of any website or mobile application you visit or use.

Who at BTF has access to my Personal Information?

We rely on role-based access and only grant access to your Personal Information to those of our employees, contractors and agents who are involved with delivering the Program services to you according to our policies and procedures. We have office locations or subsidiaries in the United States. Our employees at these locations may be required to access your Personal Information to provide you with quality services, including support team services. Our employees are obligated to respect the confidentiality of your Personal Information and are only authorized to access your Personal Information as necessary to provide you with services or support. Examples of the employees who have access to your Personal Information include our ZeroMe technical support, our data reporting and analytics staff, our development/engineering support team, and our customer support team.

Can other users view my ZeroMe profile?

No. At this time the Program does not allow other members to view your profile.

What Personal Information does BTF share with my Program Sponsor?

In general we share data with your Program Sponsor. Your Program Sponsor will be able to use such data to directly identify you. Your Program Sponsor may use the data in its discretion, including to evaluate the overall program, as well as to provide additional benefits, programs and services. Access to your data by your Program Sponsor is controlled through your Program Sponsor’s active directory controls. For more information about these controls, please contact your Program Sponsor.

In these circumstances, we limit the Personal Information to the least amount necessary to support the specific, necessary purpose of administering the Program.

If your activity information indicates there may be an abnormality or Program abuse, we may share your activity information with your Program Sponsor and make adjustments, or suspend or terminate your account, in accordance with your Program Sponsor’s instructions. For more information about acceptable Program activity, please see our Terms of Service.

Does BTF share my Personal Information with third parties?

We do not share your information with third parties to provide our services and we never sell, rent or lease your Personal Information.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, BTF is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, BTF may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In the event that we (a) undergo reorganization or liquidation under bankruptcy, or (b) are sold to a third party, any Personal Information we hold about you may be transferred to the reorganized entity or third party, in accordance with applicable laws. In any such event, the new entity will continue to use your Personal Information in accordance with and within the limits of this Privacy Policy to ensure continuation of service.

When is BTF required to disclose my Personal Information?

Government entities
We may be required to disclose your Personal Information if:

We are legally required to do so by governments, tribunals, law enforcement and regulatory agencies (for example as part of an ongoing investigation, subpoena, similar legal process or proceeding);
Disclosure is otherwise required under any applicable law, regulation, or rule; or • If we believe, in good faith, that such disclosure is necessary to protect or defend our rights or the rights of others, to assist in an investigation, or to prevent illegal activity.

Why may BTF disclose my Personal Information?

From time to time, we may need to disclose limited amounts of your Personal Information for various permissible purposes. We limit such disclosures to the least amount of information required to meet the permissible purpose. We disclose your Personal Information for the following limited purposes:

At your request to whomever you direct us to disclose the information;
To administer the Program and related services, including enrollment in the Program or any additional services;
To enhance your Program experience;
To provide you with information about the services available to you through the Program; • To ensure that you receive appropriate credit for participation in our services and other similar services provided by your Program Sponsor;
To evaluate the overall quality and effectiveness of the Program and related services; • To conduct in depth analytics about the Program;
To assess your eligibility for other programs that your Program Sponsor; or
To comply with applicable laws.

Where and how is my Personal Information and other data stored?

All your data, including any Personal Information we collect about you, is stored in cloud-based storage regions for the United States of America (USA) and typically processed in the USA where our central database is operated. Because your data is stored and processed in the USA region, it may be subject to USA laws, including the “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001” (USA PATRIOT Act), as well as the jurisdiction of the USA government, tribunals, law enforcement and regulatory agencies, which may require Us to grant them access to your data.

How is my Personal Information secured?

We are committed to protecting your data and your privacy. To ensure data security, we follow reasonable physical, electronic and managerial procedures designed to safeguard and secure your data and Personal Information. However, no company can fully eliminate security risks associated with the provision of online services.

Among the security features we use to protect your Personal Information and other data, you will be required to log-in using a username and password to access the App. We use a hosted service, Azure AD B2C, to store and protect password information. We do not store your password information directly.

What are my data protection rights?

Various laws from around the world establish varying levels of data subject rights. At BTF we strive to provide a similar level of data rights to all our members, regardless of where they live, but some of those rights are governed by local laws. In addition to the basic rights of confidentiality, those rights include:

The right of access.
The right to amend or change your data.
The right to delete your data, also called the right to be forgotten.
The right to object to processing activities.
The right to restrict processing activities.
The right to submit data protection related complaints to us and to relevant government agencies, as referenced above.

These rights are described in more detail below. You can use our online data management tool, available on your profile page, to submit data subject rights requests.

How can I access or change the Personal Information BTF has collected about me?

Your user profile is integrated to your Program Sponsor’s active directory in order to validate your eligibility to participate in the Program. You can review your Personal Information by logging into the App. You can change your Personal Information by contacting your Program Sponsor or updating your Personal Information in your Program Sponsor’s active directory. All of our users, regardless of residency, except in specific circumstances identified by local laws, have a legal right to access and correct or update the information we have collected about you. You can also request a copy of all the Personal Information and data we hold about you. We will provide you with a copy of all the data we have collected about you in a standard format (such as Excel) through a secure channel. You can contact us to request a copy of all your Personal Information or to request a change in your Personal Information through the “Data Requests” option in the App. We will respond to your request within a reasonable timeframe.

Please keep in mind that we may not be able to accommodate your request if we reasonably believe the change would violate any laws or cause the information to be inaccurate or incorrect. Additionally, we may not be able to fulfill a request where it would impose a burden on us that is disproportionate to the risk to your privacy, or where your request may affect another individual’s rights to privacy. If we are unable to fulfill a request we will provide you with the reasons why we cannot do so.

Can I request that my Personal Information and data be deleted from ZeroMe databases?

Yes, you can request that we delete your identifying information from our system. You may send an information deletion request to our support services team. You may also terminate your Program participation at any time by submitting a deletion request to your Program Sponsor. Your Membership will terminate immediately upon our receipt of a new Eligibility File from your Program Sponsor reflecting your request.

Following your deletion request, we may still receive some information about you in your Program Sponsor Eligibility Files or in the claims-related information discussed earlier in this Privacy Policy. To remove your information from these sources you will need to submit that request directly to your Program Sponsor.

Your Personal Information will also be permanently and irreversibly de identified, in accordance with the timelines above, once the Program ends and your account is canceled in accordance with the terms of the Terms of Service. You will not be able to access the Program or the App once we terminate your account.

Can I request that BTF restrict processing for some of my data?

Beyond the information necessary for enrollment, you are not required to share any additional information with us. However, choosing not to share information may limit your ability to participate in the Program as selected by your Program Sponsor. You can choose to limit the data you share with us by not inputting certain data or not using certain features. However, once you have shared information, we are unable to accommodate requests to restrict the processing of certain sets of data. If you wish for us to stop processing parts of your data, you can request that all data be deleted by cancelling your account.

Can I object to BTF’s processing of my data?

Yes, you can object to our processing of your data by contacting the Privacy Officer and notifying us that you wish for your account to be suspended while your concerns about the processing of your data are resolved. Once you feel comfortable resuming use of the Program, you can contact us to unlock your account. If you realize during the time your account is suspended that you do not feel comfortable resuming use of the Program, you can cancel your account by contacting your Program Sponsor. Your data will be deleted in accordance with our standard process, except that you will not be able to access your account while the cancellation process takes place unless you first request for the suspension to be lifted.

Can I opt-out of BTF selling my Personal Information?

BTF recognizes that you have a right to opt-out of any “sale” of your Personal Information. We do not, however, provide your Personal Information to anyone in exchange for consideration that would be considered a sale. Because we do not sell your information, we have not implemented an opt-out process.

How does BTF make changes to this Privacy Policy?

We may update this Privacy Policy from time to time to reflect changes in our information practices and services offered. If we make any material changes to this Privacy Policy, you will be notified and required

to review and accept such updated terms prior to being able to access the Program.. We may correct typographical errors, such as spelling or grammar errors, in the Policy without notifying you.

What should I do if I have a concern or complaint against BTF regarding its data privacy practices?

If you have a privacy or data use concern please contact us as provided below.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

What laws, regulations or frameworks does ZeroMe comply with?

Currently, we only provide the Program to users in the USA. We may in future provide access to the Program for users in other geographic regions. You are asked to input your home postal code during enrollment. Any discrepancy between your true residence and the information disclosed to us, and how that may affect the functionality of the App, remains your responsibility.

While we take measures to ensure that your Personal Information is stored safely with us, you should be aware that the level of data protection established in the USA is generally lower than the one established in the European Union (EU) and other countries with data protection laws similar to the EU. Nothing in this Privacy Policy limits or attempts to limit your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local Data Protection Authority.

Which Translation of this Privacy Policy is the Official Version?

Please note that any translation of this Privacy Policy is intended solely to facilitate your access to this information. The English version is the only official version of this Policy and translation inaccuracies or discrepancies, if any, are not binding and have no legal effect for compliance or enforcement purposes.

How can I contact BTF or its Data Protection Officer (DPO)?

If you have general questions about the Program or the App, you can contact our support services team at [email protected].

If you have any questions, comments or concerns about this Policy, or your rights and obligations under it, you may contact us via email [email protected] or via the “Contact Us” section of the App.

Alternatively, you can contact us by writing to:

BreakthroughFuel, LLC
Attn: Data Privacy Officer
1175 Lombardi Avenue
Green Bay, WI 54304

Last Updated: February 27, 2023