Effective Date: 1 September 2025 (replacing version 5.0 – 23 October 2022)

(We have updated the sections on personal data usage and relevant lawful bases, cookies, your rights in respect of your personal data and international transfers, and made other minor tidying updates. Governing law and jurisdiction has been removed as this is covered in our Terms & Conditions.)

1. Who are we?

1.1 We are Carbon Market Pulse Limited registered in England with company number 09194907. We own and operate this website. Please contact us if you have any questions or feedback about this policy.  You can write to us at our registered office and trading address:
Carbon Pulse
c/o Field Sullivan
9 Hare and Billet Road
Blackheath
London, UK
SE3 0RB

You can also contact us by email at [email protected]. The Carbon Market Pulse data protection representative is Mike Szabo who can be contacted by email at [email protected].

1.2 Carbon Market Pulse Limited is the controller of and is responsible for your personal data. We are registered with the Information Commissioner’s Register of Data Controllers under number ZA168321.

1.3 We are committed to safeguarding your personal data (i.e. information that can identify any living person).

2. What’s the point of this policy?

2.1 This policy tells you how we deal with your personal data. Please read on to find out what kinds of personal data we collect, how we collect it, why we collect it and our legal basis for doing so, how we protect it, to whom we disclose it, your rights in respect of it and how long we keep it.

2.2 Please do not continue to use our website unless you are completely happy with this policy. If you do continue to use our website, we will assume that you do accept it.

3. Might the policy change?

We keep this policy under regular review. We may amend the policy in the future and will notify users by posting an alert on our website for 30 days following the update. We will assume you agree to the revised policy if you use the website after the effective date shown at the top of the policy.

4. What personal or other data do we collect?

4.1 We only ever collect the personal data that we need from you and keep to a minimum the personal data we hold on an ongoing basis.

4.2 We collect and store the personal data which you give us via forms on our website – such as your name, address, email address, job title, company, phone numbers, and social media and instant messaging usernames – or when communicating with us by email or in some other way.

4.3 We may receive and store certain information, some of which may be personal data, automatically when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, information about your mobile or other device including device-type and device identifier, operating system and platform, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity on our website with date / time stamps including the pages you visited, searches you made and services purchased. We collect this information using cookies and other similar technologies.

5. How do we use your personal data and what is our legal basis for doing so?

We only process your personal data where we have a lawful basis under applicable data protection legislation. The table below sets out the purposes for which we process personal data, the categories of data involved, our lawful basis for processing, and any third parties with whom we may share the data.

We may remove, alter or otherwise use any personal data if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if we are required to do so by law or appropriate authority.

6. What about cookies?

6.1 We and/or third parties use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that we store on your browser or the hard drive of your computer if you agree. Our website’s functionality will be limited if you configure your browser to reject cookies.

6.2 Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Session cookies are temporary cookies that remain in the cookie file of your browser only until your browser is closed. They allow websites to link your actions during a browser session. Persistent cookies stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie).

6.3 Cookies are used on this website for the following purposes:

a) Session cookies: We use session cookies to enable the website to keep track of your movement from page to page and store your selections so you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the website quickly and easily without having to authenticate or reprocess each new area you visit.

b) WordPress cookies: WordPress places persistent cookies (up to one year) to remember you when you return to the site, to verify details of your logged-in status, and to customise your view of our interfaces. Click here for more information.

c) Google cookies: Persistent cookies (up to two years) are set in connection with the following Google services on our site and these cookies may involve certain non-personally identifying information being sent to Google:

Google Analytics (“GA”): We use cookies to recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and what sites the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. Click here for Google’s privacy policy and here for more information about the kinds of cookies placed by Google. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

6.4 Further information and opting out:

Our cookie banner distinguishes between “necessary” and “non-necessary” cookies. Necessary cookies are always enabled as they are absolutely essential for the website to function properly. This category only includes cookies that ensure basic functionalities and security features of the website. These cookies do not store any personal information. Non-necessary cookies (which include some of the cookies in the table above) are any cookies that may not be necessary for the website to function and are used specifically to collect personal user data via analytics, ads, and other embedded content. It is mandatory to procure user consent prior to running these cookies.

You can disable all non-necessary cookies used on our website by adjusting the settings in our cookie banner.

For further information on cookies, including how to use your browser to block them and how to delete cookies already stored on your device, visit: www.allaboutcookies.org.

If you have any questions or concerns about our use of cookies, please email us at [email protected].

7. How do we protect personal data?

7.1 Security is a high priority for us. We take appropriate technical and organisational precautions to protect your personal data.

7.2 We take appropriate technical and organisational measures to protect your personal data. However, please note that email and other electronic communications may carry inherent risks if they are not encrypted, as messages may pass through multiple networks before reaching us. While we apply reasonable security controls to protect communications once received, we cannot guarantee the security of data transmitted to us by unencrypted email, and you should consider this before choosing that method of communication.

7.3 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.

8. To whom do we disclose personal data?

8.1 Payment details including credit card numbers are supplied direct to our payment partner mentioned on our website. We do not receive such information. To ensure your details are not being used without consent, your personal data may be supplied by our payment partners to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.

8.2 We may allow access to your personal data by third parties who supply us with a service. These include the following:

a) Intuit Inc. (MailChimp– for sending of emails)
b) Our contractor who supports our operational activities;
c) Our e-commerce platform providers;
d) Our website hosts and monitoring providers;
e) Our content delivery networks provider;
f) Our provider who assists us in undertaking communications.

Our selected third parties are required by us to treat your personal data as carefully as we would and can only act on our instructions with regards to their use of your personal data.

8.3 We may also disclose personal data so far as reasonably necessary:

a) if we have reason to believe that it breaches our terms and conditions, or that such steps are necessary to protect us or others, or that a criminal act has been committed, or if there has been a complaint about content posted by you, or if we are required to do so by law or appropriate authority; or

b) in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business to the prospective seller or buyer.

8.4 Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of personal data that we collect and process. If you follow links to other websites, their privacy policies will apply. If you share information directly with other organisations (for example, payment providers or partners featured on our website), their use of your information will be governed by their own policies. We encourage you to review those policies carefully.

9. What are my rights in respect of my personal data?

9.1 You have the following rights in respect of your personal data:

a) where you have registered to our website on an individual basis, to withdraw your consent to us contacting you about our goods and services or our third party partners contacting you about their goods and services at any time;
b) where you have registered to our website as part of your business requirements, to object to us processing your personal data for direct marketing purposes;
c) to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data;
d) to request correction of the personal data held by you;
e) to request a copy of your personal data which we hold about you and check that we are lawfully processing it.
f) the right in certain circumstances to:

• Have your personal data erased
• Restrict processing of your personal data
• Object to the processing of your personal data
• Have your personal data transferred to a third party

If you wish to withdraw your consent, then you can do this at any time by contacting us at [email protected].

If you wish to exercise any of your other rights listed in this policy, or that you have in law, then please contact our data protection representative Mike Szabo at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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

10. Complaints

If you have an issue or a complaint arising under this policy, then in the first instance please contact our data protection representative Mike Szabo at [email protected].

If you are not satisfied with our handling of your issue or complaint then you have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk/concerns/).

11. International transfers

The data that we collect from you will primarily be processed and stored within the United Kingdom (UK) and European Economic Area (EEA).  However, we will transfer your personal data to the following third parties based outside of the UK and EEA who host your personal data on our behalf:

a) Intuit Inc. (MailChimp) – host in the US
b) where you have registered to our website as part of your business requirements, certain third party content providers (see 5 above) – based in various countries.

Whenever we transfer your personal data out of the UK and EEA to third parties, we ensure a similar degree of protection is afforded to it by ensuring that we have in place specific standard contractual terms approved for use in the UK and EEA which give the transferred personal data the same protection as it has in the UK and EEA, namely the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

Before making any international transfer of personal data, we carry out a transfer risk assessment (TRA) to evaluate the legal and practical risks associated with the destination country. Where our assessment identifies risks, we implement additional safeguards – such as encryption, pseudonymisation, or data minimisation – to ensure your personal data receives a level of protection essentially equivalent to that in the UK and EEA.

We use the UK Addendum to the EU Standard Contractual Clauses (SCCs) as our safeguard for international transfers. A summary of these safeguards is available on the UK Information Commissioner’s Office (ICO) website.

12. Retention

We retain personal data from closed accounts for 10 years in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law. However, in some circumstances you may ask us to delete your data.

When we no longer need to keep your personal data, we undertake to delete it and dispose of it securely.

13. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Version 6.0 –  1 September 2025