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C:Pesa® Privacy Policy

INTRODUCTION

Carbon Pesa Limited (“C:Pesa®”), is a private limited company registered in England and Wales with registered number 13779755, whose registered office is at 6 Brookshill Gate, 55 Brookshill, Harrow Weald, Middlesex, United Kingdom HA3 6RU, which controls and operates the C:Pesa® Website. 

C:Pesa® respects your privacy and is committed to protecting your personal data and wants you to feel comfortable using this website (“C:Pesa® Website”). This privacy policy (as amended, updated or replaced from time to time, the “C:Pesa® Privacy Policy” or “this privacy policy”) is issued on behalf of C:Pesa® so when we mention “C:Pesa®”, “we”, “us” or “our” in this notice, we are referring to C:Pesa® which is responsible for processing your data. For the purposes of this C:Pesa® Website and applicable data protection legislation, C:Pesa® is the controller.

This privacy policy states what data we may collect and how we may use that information and that the data we hold about you should be processed lawfully and fairly. It should be accurate, relevant and not excessive. The information should be kept up to date, where necessary, and not retained for longer than necessary. It should be kept securely to prevent unauthorised access by other people. You have the right to see what is held about you and to correct any inaccuracies. 

PERSONAL DATA 

Wherever we talk about Personal Data below (“Personal Data”), we mean any information that can either itself identify you as an individual (“Personally Identifying Information”) or that can be connected to you indirectly by linking it to Personally Identifying Information.

By using the Company’s website, you signify your assent to the C:Pesa’s® Privacy Policy. If you do not agree with C:Pesa’s® Privacy Policy, please do not use the C:Pesa® Website.

Your Personal Data is protected in the UK by the General Data Protection Regulation (Regulation (EU) 2016/679) (the “UK GDPR”) and the Data Protection Act 2018 (together the “Data Protection Legislation”), including any subsequent amending, supplemental or replacement legislation and other legislation in other territories. This provides, amongst other things, that the Personal Data we hold about you should be processed lawfully and fairly. 

YOUR QUESTIONS ABOUT YOUR PERSONAL DATA

If you have any questions about the C:Pesa’s® Privacy Policy or our privacy practices, including any requests to exercise your legal rights, please contact us using the email box: contactus@c-pesa.com.

Depending on where you are resident or otherwise located, you have the right to make a complaint any time to the relevant national supervisory authority for data protection issues. In the UK, for example, you can make a complaint at any time to the Information Commissioner’s Office (ICO) (https://ico.org.uk). We would, however, appreciate the opportunity to deal with any concerns you may have before you approach any national supervisory authority, so please contact us in the first instance. 

THE TYPE OF DATA WE COLLECT 

There will be times, such as when you request information or contact us, when we will need to obtain personally identifiable information from you or about you. To respond to your query effectively, we may collect, use, store and transfer the following kinds of personal data about you: 

  • Identity Data includes your full name, maiden name, username, email, phone number or similar identifiers. 
  • Contact Data includes postal address, email address and telephone number. 
  • Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the C:Pesa® Website. 
  • C:Pesa® Appliance data includes a variety of information which is collected through the C:Pesa® Appliance installed by energy generators that will be sent through Application Programming Interface (API) to the C:Pesa® Platform as part of our contractual obligation.
  • Transaction Data includes details about Digital IRECs generated and/or traded on the C:Pesa® Website, financial data regarding payments to and from you and other details of services we have provided to you. 
  • Usage Data includes information about how you use our website, products and services. 

We also collect, use and share Aggregated Data. “Aggregated Data” means statistical or demographic data about several individuals that has been combined to show general trends or values without identifying individuals within the data. Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 

For example, we may use your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any “Special Categories of Personal Data” (as defined in Article 9(1) of the UK GDPR) about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

We may use artificial intelligence tools, automated systems and data enrichment services to enhance our Services and improve your user experience. This includes processing your personal data (such as your usage patterns, company information, and engagement data) through AI systems to generate insights, personalise content, and create analytics reports. We may combine your data with information from third-party sources to better understand your professional interests and deliver more relevant services. 

We also use AI and data enrichment to create aggregate, anonymised reports showing readership patterns by firm type, sector, and geographic location for our readers and commercial partners. Such processing is based on our legitimate interests in improving our Services and providing valuable market insights, while ensuring appropriate safeguards are in place to protect your personal data. 

Our AI systems may make automated decisions that significantly affect you, including credit assessments, transaction approvals, and trading recommendations. Under data protection law, you have specific rights regarding automated decision-making: the right to be informed when automated processing significantly affects you, the right to request human review of automated decisions, the right to object to certain automated processing (though this may limit service availability), and the right to understand the logic behind automated decisions that impact the user. 
We process your data through AI systems based on different legal grounds: contract performance for service delivery, and legitimate interests for business optimization, commercial data product development, and third-party data licensing in anonymized form. To exercise these automated decision-making rights, contact: contactus@c-pesa.com .

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we have to cancel a service you have with us but we will notify you if this is the case at the time. 

WE COLLECT YOUR PERSONAL DATA IN DIFFERENT WAYS

C:Pesa® has obtained your data because you have provided this data to us. 

This includes Personal Data you provide when you: 

  • access the C:Pesa® Website;
  • request a demonstration;
  • register on the C:Pesa® Platform;
  • give us feedback or contact us,

and, for renewable energy generators who have had C:Pesa® Appliance installed on their site, when technical information is collected by the C:Pesa® Appliance.

We collect Personal Data from your interaction with the C:Pesa® Website. Depending on your device settings (see the link to our Cookie Policy below), whenever you interact with the C:Pesa® Website, we may automatically record information from your browser or device. This may include technical data and information about your visit to the C:Pesa® Website (including data and time, page response times, download errors, length of visits to certain page, page interaction information such as scrolling, clicks, and mouse-overs, methods used to browse away from the page and devices used to access the C:Pesa® Website. 

WE USE YOUR PERSONAL DATA DISCLOSED AND DESCRIBED HERE

All Personal Data received will be treated as confidential and only be used for our legitimate interests, or where we need to perform the contract we are about to enter into or have entered into with you, or where we need to comply with a legal or regulatory obligation. 

Your Personal Data will not be sold, rented or provided by us to any other third parties unless you have agreed otherwise. 

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below. 

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer, client, reader, user or attendee.(a) Identity
(b) Contact
(c) Generation facility details
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To register you for our newsletter or an event, whether virtual or physical (and to administer/organise such event), as part of which we may provide your personal data to our event sponsors.(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youa) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
To process your data through AI systems and data enrichment services to generate personalised insights and create aggregate, anonymised analytics reports showing readership patterns(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Technical
Necessary for our legitimate interests (to improve our Services and provide anonymised market intelligence to readers and partners)
To process payments through Stripe and manage user authentication and membership access through MemberPress(a) Identity
(b) Contact
(c) Financial
(d) Technical
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to provide secure payment, login and membership services)
To manage customer relationships, email marketing, and engagement analysis through HubSpot CRM(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Consent (for marketing)
(c) Necessary for our legitimate interests (customer relationship management and business development)

INTERNATIONAL TRANSFERS 

We share your Personal Data within the C:Pesa® group and our commercial partners globally. Given the location of C:Pesa’s® international group companies, your Personal Data may be transferred outside the United Kingdom or the European Economic Area (“EEA”) and where necessary, to affiliate group companies, including our subsidiary and affiliates in Kenya and other jurisdictions where we conduct business or data processing activities.

Whenever we transfer your Personal Data out of the United Kingdom or EEA, we implement appropriate safeguards including standard contractual clauses, international data transfer agreements, or other approved data transfer mechanisms wherever required, adequacy decisions for approved jurisdictions, additional contractual protections and technical safeguards, and regular assessments of data protection standards in recipient countries in order to ensure that your rights as a data subject are complied with in accordance with all applicable laws and that effective legal remedies are available. We may also transfer anonymized and aggregated data globally without geographic restrictions to support our commercial data products, AI model development, and third-party licensing activities, as such data does not identify individuals and is not subject to international transfer restrictions.

THIRD-PARTY LINKS 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our C:Pesa® Website, we encourage you to read the privacy notice of every website you visit. 

USE OF COOKIES 

Like many websites, the C:Pesa® Website uses cookies to enhance your user experience and to remember your personal settings. A cookie is a small piece of information that the C:Pesa® Website stores in your web browser. 

Most web browsers accept cookies, but you may choose to configure yours to refuse cookies. By doing so, some features of the C:Pesa® Website may become inaccessible or not function properly. 

For more information about the cookies we use, please see our Cookie Policy

DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. 

While we cannot ensure that loss, misuse or alteration will not occur, we have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

DATA RETENTION 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

We implement industry-standard security measures including encryption, access controls, and breach detection systems. We maintain documented procedures to respond to suspected data breaches and will notify you and applicable regulators as legally required.

While we employ robust technical and organizational safeguards, no electronic system can guarantee absolute security. We work continuously to enhance our security measures in line with evolving threats and regulatory requirements. 

COMMERCIAL DATA USE

C:Pesa® may process and retain anonymized, aggregated, and derivative datasets created from your data. We may use such datasets as we consider appropriate from time to time, including, for example (but without limitation), to:

  • Develop commercial data products and market intelligence services;
  • Train proprietary AI models and algorithms for renewable energy optimization;
  • License anonymized insights to third-party partners and research institutions;
  • Create industry benchmarks, analytical tools, and predictive models; and/or
  • Support academic research and development of sustainable energy solutions.

This commercial use is based on our legitimate business interests and may assist us in advancing our renewable energy technology and supporting the development of innovative energy solutions. Individual users cannot be identified from these commercial datasets, and appropriate technical and organizational measures are implemented to ensure anonymization.

Revenue generated from commercial data licensing shall be used as we consider appropriate but may, amongst other things, help support our platform development and service improvements that may benefit users.

YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data, including the right to request access to your Personal Data, the right to request correction of your Personal Data, the right to request erasure of your Personal Data, the right to object to processing of your Personal Data, the right to request restriction of processing your Personal Data, the right to request transfer of your Personal Data and the right to withdraw consent. 

Please note that certain data subject rights may be limited in specific circumstances where:

  • Data has been fully anonymized, and individual identification is no longer possible;
  • Legal or regulatory obligations require data retention (e.g., financial regulations, litigation holds);
  • Processing is essential for establishing, exercising, or defending legal claims.

We will assess each request individually and explain any applicable limitations with reference to specific legal grounds. Where partial fulfilment is possible, we will provide the information we can while explaining any restrictions.

If you wish to exercise any of the rights, please contact our designated data privacy email box: contactus@c-pesa.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated. 

FURTHER INFORMATION

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the United Kingdom. They make a lot of information accessible to consumers on their website, and they ensure that the registered details of all data controllers, such as Carbon Pesa Limited, are available publicly. You can access them at https://ico.org.uk/

REVIEW OF THE C:PESA® PRIVACY POLICY 

We reserve the right to make any changes and corrections to this C:Pesa®Privacy Policy. We invite you to refer to this page regularly to check current and new, additional information. The last revision of this policy was made on 6th January 2026.

CONTACT

Carbon Pesa Limited is registered as a data controller under the Data Protection Act 2018 (Registration Number ZB409003). If you have any questions about this policy or about this C:Pesa® Website or any services accessible through it please contact us using the email box: contactus@c-pesa.com.