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Privacy Policy

Last updated: 9/11/2026

1. Introduction

Welcome to SOE (“Soldiers of Earth”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and safeguard your information when you use our sustainability scoring platform. This policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the California Consumer Privacy Act (CCPA).

2. Data Controller and Data Protection Officer

SOE is the data controller responsible for your personal data. For data protection inquiries, please contact our Data Protection Officer at [email protected].

3. Information We Collect

We collect the following types of information:

  • Account Information: Name, email address, profession, and location
  • Sustainability Data: Your responses to assessment questions including energy usage, transportation habits, diet choices, and lifestyle practices
  • Profile Data: Optional information you choose to share like bio, certifications, and portfolio links
  • Usage Data: How you interact with our platform, features used, and engagement metrics
  • Technical Data: IP address (anonymized where possible), browser type, device information, and cookies
  • Consent Records: Records of your cookie and privacy preferences, including timestamps

4. Legal Basis for Processing (GDPR Article 6)

We process your personal data under the following legal bases:

  • Consent (Art. 6(1)(a)): For analytics cookies, marketing communications, and optional profile features. You may withdraw consent at any time.
  • Contract (Art. 6(1)(b)): For account creation, score calculation, and platform features you request.
  • Legal Obligation (Art. 6(1)(c)): For retaining records required by law (e.g., tax records for paid services).
  • Legitimate Interests (Art. 6(1)(f)): For platform security, fraud prevention, and service improvement.

5. How We Use Your Information

We use your information to:

  • Calculate and display your personal sustainability score
  • Create and manage your user profile
  • Generate leaderboards and directories (only if you opt-in to public profile)
  • Improve our assessment methodology and platform features
  • Send you relevant updates about your sustainability journey
  • Prevent fraud and ensure platform security
  • Analyze platform usage to improve user experience (only with your consent)

6. Data Sharing and Disclosure

We do not sell your personal information. We only share data in the following circumstances:

  • Public Profiles: If you choose to make your profile public, your name, score, profession, and sustainability achievements will be visible to other users
  • Service Providers (Data Processors): We use trusted third-party services that act as data processors under GDPR Article 28:
    • Supabase — Database hosting and authentication (data stored in EU/US regions)
    • PostHog — Product analytics (only loaded with your consent)
    • Vercel — Web hosting and deployment infrastructure
    • Email delivery — Transactional and notification emails
  • Legal Requirements: When required by law or to protect our rights

7. International Data Transfers

Your data may be processed in countries outside the European Economic Area (EEA), including the United States. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Data Processing Agreements (DPAs) with all our service providers
  • Encryption of data in transit (TLS) and at rest

8. Your GDPR Rights

Under the GDPR, you have the following rights:

  • Right of Access (Art. 15): Request a copy of your personal data
  • Right to Rectification (Art. 16): Correct inaccurate or incomplete data
  • Right to Erasure (Art. 17): Request deletion of your personal data (“right to be forgotten”)
  • Right to Restriction (Art. 18): Limit the processing of your data
  • Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format
  • Right to Object (Art. 21): Object to processing based on legitimate interests
  • Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting prior processing
  • Right to Lodge a Complaint (Art. 77): Complain to your local supervisory authority

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

9. Cookies and Tracking Technologies

We use cookies and similar technologies in the following categories:

  • Essential Cookies (always on): Required for authentication, security, and core platform functionality. These cannot be disabled.
  • Analytics Cookies (opt-in): Used to understand how visitors interact with our platform, including Google Analytics 4, PostHog, and Vercel Analytics. Only loaded after you give consent.
  • Marketing Cookies (opt-in): Used for personalized advertising and retargeting. Only loaded after you give consent.

You can change your cookie preferences at any time using the Cookie Settings button below or through your browser settings. We record your consent choices for audit purposes.

10. Your Privacy Choices

You have control over your data:

  • Choose whether your profile is public or private
  • Edit or delete your sustainability data at any time
  • Request account deletion and data export
  • Opt-out of marketing communications
  • Control cookie preferences through our consent banner or browser settings
  • Withdraw consent for analytics and marketing at any time

11. Data Security

We implement appropriate technical and organizational measures to protect your data, including encryption in transit (TLS 1.2+) and at rest, Row Level Security (RLS) on all database tables, secure server-side key management, rate limiting, and regular security audits. Access to personal data is restricted to authorized personnel only. However, no system is 100% secure, and we cannot guarantee absolute security.

12. Data Retention

We retain your data as long as your account is active. If you delete your account, we will remove your personal information within 30 days, though anonymized, aggregated data may be retained for research and platform improvement purposes. Cookie consent records are retained for the duration required to demonstrate compliance with GDPR accountability obligations.

13. Children's Privacy

Our platform is not intended for children under 13 (under 16 in the EU per GDPR Article 8). We do not knowingly collect data from children. If you believe we have collected such data, please contact us immediately and we will delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or through the platform. Your continued use after changes indicates acceptance of the updated policy.

15. Contact Us

If you have questions about this Privacy Policy, your data, or wish to exercise your rights, please contact us at [email protected]. For EU residents, you may also lodge a complaint with your local data protection supervisory authority.

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