Privacy Policy

This Privacy Policy is effective as of March 1, 2026, and replaces all previous versions.

1. PREAMBLE 

Position Green Group and its Affiliates (“Position Green”, “we”, “our”, “us”) considers the safeguards of Personal Data of Users of its Services of paramount importance. For this reason Position Green complies with the EU General Data Protection Regulation 2016/679 (“GDPR”). 

This Privacy Policy sets out how Position Green will handle your Personal Data when using our Services.

2. DATA CONTROLLER 

For the purpose of this Privacy Policy, Position Green is the Data Controller of your Personal Data.

3. EMPLOYEES, SERVICE PROVIDERS AND POSITION GREEN 

We may disclose your Personal Data to some of our employees and/or our service providers insofar as reasonably necessary for the purposes set out in this Privacy Policy. 

Position Green has in place written agreements with each of its service providers that are compliant with GDPR. Nevertheless, Position Green remains responsible for the processing of Personal Data within its Services. 

Except as provided in this Privacy Policy, we will not share your Personal Data to any third party.

4. COOKIES

To find out more about how we use cookies, please see our Cookies Policy.

5. BOOK A DEMO, NEWSLETTER, E-BOOK

5.1. Personal Data we collect 

5.2 How we use your Personal Data and on which legal basis

a. Business operation

We use your Personal Data to communicate effectively with you, conduct our business and respond to your demo requests (Article 6.1.(b) and 6.1.(f) GDPR).

We use your email address for the sole purpose of sending you the newsletter. The processing of the Personal Data entered into the newsletter subscription form occurs exclusively on the basis of your consent (Art. 6.1.(a) GDPR). You may revoke this consent at any time, by clicking on the “Unsubscribe” link in the newsletter. 

We use your email address for the sole purpose of sending you the e-book. The processing of the Personal Data entered into the e-book form occurs exclusively on the basis of your consent (Art. 6.1.(a) GDPR). 

b. Advertising

We may use your Personal Data to deliver targeted advertisements about our Services on social media platforms and search engines, subject to your informed consent (Article 6.1.(a) GDPR). You may revoke this consent at any time, by sending an email to privacy@positiongreen.com. 

c. Communicating with you 

We use the Personal Data we collect to communicate with you on our Services and related offers where you have shown interest in. We do this on the basis of our legitimate interests (Art. 6.1.(f) GDPR).

5.3. How do we share your Personal Data and with whom

If you book a demo with Position Green via our Website, the above Personal Data that you submit to us will be forwarded to our calendar services provider.

Subject to your consent as explained in Section 5.2.(b), access to your Personal Data is also granted to, social media platforms and search engines to enable targeted advertising on their platforms. 

5.4. How long we store your Personal Data

Your Personal Data submitted for booking a demo will be stored within our calendar services provider’s database for the period defined by its privacy policy and in our internal computer systems as long as you are still interested in a Position Green demo.

The Personal Data you submitted for the purpose of subscribing to the newsletter will be stored by Position Green until you unsubscribe from the newsletter, following which your Personal Data will be deleted from the newsletter distribution list.

The Personal Data you submitted for the purpose of downloading our e-book will be stored by Position Green in accordance with our legal and regulatory obligations. 

In the event of advertising, your Personal Data will be stored within the social media platforms’ and search engines’ databases for the period defined by their respective privacy policies and in our internal computer systems in accordance with our legal and regulatory obligations, until you remove your consent.

6. PLATFORM

6.1. Personal Data we collect 

6.2. How we use your Personal Data and on what legal basis

a. Create and manage your account to use the Services

By accepting to use the Services, you and your end customers become Users of the Platform. We process required Personal Data to perform our contractual obligations toward you and your end customers. This includes: setting up a User Account and providing important information related to the Services (Article 6.1.(b) GDPR).

b. Customer Support

We process your Personal Data to administer our customer relationship with the company you represent, including managing your user account, providing customer support, and documenting support matters (Article 6.1.(b) GDPR).

c. Prevent fraud and protect our Services.

We have a legitimate interest in ensuring the ongoing security and proper operation of our Services and associated IT services and networks by enabling secure logins (Article 6.1.(f) GDPR).

d. Send communications to you

We have a legitimate interest in providing you with updates on our Services and related offers where you have purchased or shown interest in similar services from us (Article 6.1.(f) GDPR).

e. General aggregation of Personal Data

We have a legitimate interest in creating aggregate data sets for benchmarking purposes as an additional service to Users (Article 6.1.(f) GDPR). These data sets do not allow (directly or by inference) the re-identification of any data subject as the source of such data. 

f. Legitimate interest

We may process your information based on our legitimate interests in communicating with you and managing our interactions as well as performing obligations to you and your end customers regarding our Services (Article 6.1.(f) GDPR).

6.3. How long we store your Personal Data

We will keep your Personal Data for as long as we have a contractual relationship with you. We will retain your Personal Data, unless you make a deletion request which will be handled in compliance with our legal and  regulatory obligations.

7. POSITION GREEN ACADEMY

7.1. Personal Data we collect

7.2. How we use your Personal Data and on what legal basis

a. Providing courses 

We use your Personal Data to enable you to navigate the Position Green Academy, to enroll and participate in courses and programs on the Position Green Academy, to learn effectively in such courses and programs, to obtain products and services on the Position Green Academy such as certificates. We offer products and services on the basis that it is necessary to fulfil our contractual obligations to you under the Terms of Use (Art. 6.1.(b) GDPR).

b. Communicating with you

We use information we collect to communicate with you, including answering your course and platform questions and notifying you of course and Position Green Academy maintenance and updates. We do this on the basis of our legitimate interests in keeping learners up to date about our courses and responding to learner questions (Art. 6.1.(f) GDPR). We also use the Personal Data we collect to communicate with you on our Services and related offers where you have shown interest in (Art. 6.1.(f) GDPR). 

c. Advertising

We may use your Personal Data to deliver targeted advertisements about Position Green Services on social media platforms and search engines, subject to your informed consent (Article 6.1.(a) GDPR). You may revoke this consent at any time, by sending an email to privacy@positiongreen.com. 

7.3. How do we share your Personal Data and with whom

Subject to your consent as explained above, access to your Personal Data is also granted to, social media platforms and search engines to enable targeted advertising on their platforms. 

7.4. How long we store your Personal Data

We will retain your Personal Data for as long as your account is active or as needed for the Position Green Academy or to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise permitted by applicable law.

Your Personal Data submitted will be stored within our search engines and social media platform’s database for the period defined by their respective privacy policies.

8. WEBINARS AND EVENTS

8.1. Personal Data we collect

8.2. Session’s recording

We may record the Webinars and/or Events for the purpose of (i) publishing it on the Platform and the Website, (ii) promoting our Services and (iii) making it available for invitees who would like to replay it or could not attend it. If the Webinar and/or Event is recorded, we will inform you and take measures to keep the participants list anonymous.

8.3. How we use your Personal Data and on what legal basis

a. Participation in to Webinars and/or Events

We use your Personal Data to manage the attendance to our Webinars and/or Events and keep you updated about them. This includes sending you notifications before the Webinars and/or Events take place so that you can participate in them (Article 6.1.(b) GDPR).

b. Communication

We use the Personal Data we collect to communicate with you on our Services and related offers where you have shown interest in. We do this on the basis of our legitimate interests (Art. 6.1.(f) GDPR).

In addition, when applicable, we use your Personal Data to communicate the name of participants to Position Green’s co-host of the Webinar and/or Event. The legal basis for this processing is our legitimate interest in effectively organizing and managing the event in collaboration with our co-host (Article 6(1)(f) GDPR). 

c. Promotion

We may use your Personal Data to inform you of similar future Webinars and/or Events or to send surveys about Webinars and/or Events (Article 6.1.(f) GDPR).

d. Advertising

We may use your Personal Data to deliver targeted advertisements about Position Green products and services on social media platforms and search engines, subject to your informed consent (Article 6.1.(a) GDPR). You may revoke this consent at any time, by sending an email to privacy@positiongreen.com.

8.4. How do we share your Personal Data and with whom

Your Personal Data submitted for attending our Webinar will be stored within our webinar hosting provider’s database for the period defined by its privacy policy and in our internal computer in accordance with our legal and regulatory obligations.  

Subject to your consent as explained above, access to your Personal Data is also granted to, social media platforms and search engines to enable targeted advertising on their platforms.

As mentioned above, your Personal Data may also be shared with Position Green’s cohost of the Webinar and/or Event, if applicable.

8.5. How long we store your Personal Data

Your Personal Data submitted for attending our webinar will be stored within our webinar hosting provider’s and search engines and social media platform’s database for the period defined by their respective privacy policies and in our internal computer in accordance with our legal and regulatory obligations.

9. PARTNER

9.1. Personal Data we collect

9.2. How we use your Personal Data and on which legal basis

We use your Personal Data to communicate effectively with you, conduct our business and respond to your partnership requests (Article 6.1.(b) and 6.1.(f) GDPR).

9.3. How long we store your Personal Data

Your Personal Data submitted for a partnership request will be stored within our internal computer systems as long as you are still interested in a Position Green demo. 

10. CAREERS

10.1. Personal Data we collect 

10.2. How we use your Personal Data and on which legal basis

a. Manage recruitment and applications

We process your Personal Data to review profiles and applications submitted to us, assess your suitability for roles, and communicate with you about your application and recruitment process. This processing is necessary for the purposes of our legitimate interests in managing and conducting our recruitment activities (Article 6.1.(f) GDPR).

b. Inform you about current and future job opportunities

We may process your Personal Data to inform you about current and future job opportunities, including contacting you directly about specific roles and providing general updates about vacancies within our organisation. We do this on the basis of our legitimate interests in identifying and engaging with potential candidates (Article 6.1.(f) GDPR).

You may object to such communications at any time, by sending an email to privacy@positiongreen.com.

c. Send surveys related to recruitment

We process your Personal Data to contact you and ask for your participation in surveys related to our recruitment process or candidate experience. We have a legitimate interest in collecting feedback to improve our recruitment practices (Article 6.1.(f) GDPR).

10.3. How long we store your Personal Data

We retain your Personal Data for as long as necessary to fulfil the purposes described above, in accordance with our legal and regulatory obligations. Your Personal Data will be stored with our service providers for the period defined by their respective privacy policies

11. YOUR RIGHTS OVER YOUR PERSONAL DATA

11.1. Your rights

You have the following rights regarding your Personal Data:

1. To know how we are processing your Personal Data and to access to your Personal Data held by Position Green (DSAR-01); 
2. To request the rectification of inaccurate or incomplete Personal Data (DSAR-02); 
3. To request the erasure of your Personal Data when, among others, such data is no longer necessary for the initial purposes for which it was initially collected, in accordance with applicable law (DSAR-03); 
4. To restrict our processing of your Personal Data, under certain circumstances (in which case we will only retain the Personal Data for the exercise and/or defence of Position Green’s rights) (DSAR-04); 
5. To request the portability of your Personal Data, which will allow you to obtain and reuse the personal data in a usable electronic format for your own purposes and across different services without hindrance to usability, including its transmission to another third party (DSAR-05); 
6. To withdraw the consent you may have granted to a specific processing, at any time (DSAR-06);
7. To object to the processing of your Personal Data, in particular where we process your Personal Data based on our legitimate interests or for direct marketing purposes (DSAR-07).

11.2. How to exercise your rights

In order to exercise any of these rights, please send your Data Subject Access Request by email to privacy@positiongreen.com specifying the code of your specific request.

11.3. Right to lodge a complaint with supervisory authority 

In accordance with Article 77 GDPR you have the right to lodge a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that Position Greens processing of your Personal Data infringes the GDPR.

Please visit the website of your relevant supervisory authority for more information on how to submit such a complaint.

12. SECURITY OF YOUR PERSONAL DATA

Security is in our DNA and embedded in our people, processes, and technologies. We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your Personal Data. We have implemented several management systems that attests of our security maturity, available at on our Trust Portal.

13. THIRD-PARTY WEBSITES

The Website and the Position Green Academy may contain links to third party websites. Position Green is not responsible for the privacy policies or practices of third party websites, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.

14. SUBPROCESSORS

Position Green leverages certain third-party service providers to assist us in delivering and maintaining our Services. These Subprocessors are carefully evaluated, selected and bound by contractual obligations that match our own stringent data security and privacy standards, available on the Trust Portal.

We employ commercially reasonable measures to ensure Subprocessors only process your Personal Data for the specific purposes outlined in this Privacy Policy and solely in accordance with our documented instructions. 

We implement Data Processing Agreements (DPAs) as well as Standard Contractual Clauses (SCCs) in accordance with Article 46(2)(c) of the GDPR, where applicable, with the Subprocessors that require them to:

• Implement and maintain robust technical and organisational safeguards to protect the confidentiality and integrity of your Personal Data.
• Process your Personal Data exclusively in accordance with our instructions and all applicable laws and regulations.
• Refrain from disclosing your Personal Data to any unauthorised third party.
• Upon the termination of our agreement with the Subprocessor, delete or return your Personal Data at our direction.

Additional information about the Subprocessors Position Green uses to support delivery of our Services is set forth in our list of Subprocessors.

15. CONTACT

If you have any questions about this Privacy Policy or our treatment of your Personal Data, please write to our Data Protection Officer (“DPO”) by email to privacy@positiongreen.com.

16. MODIFICATION OF THE PRIVACY POLICY

We may update this Privacy Policy from time-to-time by posting a new version on our Website. All changes are effective immediately upon communication. We encourage you to occasionally check this page to ensure you are happy with any changes to the Privacy Policy.

Material modifications will be subject to notification by Position Green by Website notice, email or any other form of communication.

17. DEFINITIONS

Any capitalised term used herein will have the meaning ascribed to it under this Section.