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