Privacy Policy

Tradewater, LLC Privacy Policy
(updated and effective August 1, 2021)

1.  Application of This Policy

1.1. Tradewater, LLC (“we”, “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies or practices, you must stop accessing or using tradewater.us (our “Website”) and cease participation in our programs, such as our Carbon Neutral Collective Program. You are deemed to be in agreement with this policy by accessing or using our Website, participating in our programs, or purchasing Tradewater carbon offset credits.

1.2. This policy describes the types of information we may collect from you or that you may provide when you visit our Website and our practices for collecting, using, maintaining, protecting and disclosing that information. This policy also applies to all buyer information we collect online and offline.

1.3. This policy applies to information we collect on the Website and in e-mail and other communications between you and us. It does not apply to other websites operated by third parties, or any third party (including our affiliates) or through any application or content that may link to or be accessible from our Website. When you access a third-party website (such as a social networking website), we are not responsible for the privacy practices of that site or the relevant third party. You should review the privacy policies of each website you visit and each social networking service you use (including understanding how you can change your privacy settings with those services).

2. Information We Collect About You and How We Collect It

2.1. We collect several types of information from and about our users including:

(a.) information by which you may be personally identified, such as your name, postal address, e-mail address, or any other identifier by which you may be contacted online or offline (“personal information”);

(b.) information that is about you but individually does not identify you, such as your IP address, some types of profile information and content that you post on the Website; and

(c.) information about your internet connection, the equipment you use to access our Website and usage details.

2.2. We collect this information directly from you when you voluntarily provide it to us and/or automatically as you navigate through the Website.

2.3. Information You Voluntarily Provide to Us.

The information we collect on or through our Website may include:

(a.) information that you provide by filling in forms on our Website or engaging with certain services provided by our Website, such as information you provide to us at the time of purchasing our carbon offset credits, signing up for and participating in our programs or features and/or placing orders on our Website;

(b.) records and copies of your correspondence (including e-mail addresses) if you contact us; and

(c.) details of transactions you carry out through our Website and of the fulfillment of your orders. You will be required to provide credit card information before making a payment to Tradewater for carbon offset credits.

2.4. Use of Cookies

We use “cookies” on this Website. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server of the website that issued the cookie to you. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personal information on our site.

Depending on your web browser, you may have the ability to accept or decline cookies. Most web browsers default to accept cookies but enable you to configure settings to decline them. For further information about disabling cookies you can visit www.allaboutcookies.org. If you choose to decline cookies, you may not be able to use features of the Website that depend on cookies.

3. Third Party Use of Cookies and Other Tracking Technologies

 3.1. Some content or applications on our Website are served by third parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

4. How We Use Your Information

4.1. We use information that we collect about you or that you provide to us:

(a.) to present our Website to you and others, including the content, features, applications and functionalities made available via our Website;

(b.) to provide you with information about how you can participate in our objective to aid the environment by reducing carbon emissions and other matters that you may be interested in. This information will be limited to our programs and those of our third-party partners;

(c.) to provide you with notices about your account;

(d.) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

(e.) to notify you about changes to our Website;

(f.) to allow you to participate in interactive features on our Website;

(g.) in any other way we may describe when you provide the information; and

(h.) for any other purpose with your consent.

5. Disclosure of Your Information 

5.1. We use Stripe, a credit card processing company, to bill users for goods and services. We may, from time to time, also use WooCommerce via WordPress, an analytics aggregator, to log actions and find bugs in our software. These companies do not retain, share, store or use personal information for any secondary purposes beyond fulfilling payment orders (Stripe) and logging product actions (WooCommerce via WordPress).

5.2. We may aggregate data about our users and information that does not identify any individual (“Aggregate Anonymized Data”). We may use and disclose Aggregate Anonymized Data without restriction.

5.3. In the event of a merger, divestiture, restructuring, reorganization, acquisition, dissolution or other sale or transfer of some or all of our assets, in which personal information held by us about our website users are among the assets transferred to the buyer, personal information may be transferred.

5.4. Personal information may also be used to stay in touch with our supporters about activities and to expand our supporter base;

You may withdraw your consent to our sharing of your personal information by emailing us at info@tradewater.us.

5.5. We may also disclose your personal information:

(a.) to comply with any court order, law or legal process, including to respond to any government or regulatory request;

(b.) to enforce or apply our terms of use or terms of sale (if applicable), including for billing and collection purposes;

(c.) to transfer to a company that Tradewater is acquired by or merges with; or

(d.) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5.6. Your personal information is kept indefinitely. Further, some information may be retained if it is contained in deleted emails or electronic documents which are archived by our company in compliance with our standard archival processes but which, in the ordinary course of operations, are not accessible by the individuals who created or received such emails or documents. If you would like to be removed from our database or change any information, you may contact us at the email of the Data Collection Officer listed below. If you have requested communications from us through our website or third-party partners and later change your mind, you may ask that your name and contact information be removed from our distribution list. You can send such a request to the email or mailing addresses at the end of this policy. Web browsers include options which permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.

5.7. Participants in The Carbon Neutral Collective Program further agree to additional disclosures of their personal information, as provided for in the Carbon Neutral Collective Terms of Use, which are made available when signing up for that program.

6. Your California Privacy Rights

6.1. Accessing Your information. California Civil Code section 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail or write us using the contact details found in the “Contact Information” section below.

7. Data Security

7.1. The security of our user data is very important to us. We store your information securely, using industry-compliant encryption technology. When you enter sensitive information (such as a credit card number) on our web forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

7.2. The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of our Website. If you have created an account, you are responsible for maintaining the security of your login credentials in accordance with the instructions and policies of the relevant social media provider.

7.3. The transmission of information via the internet is not completely secure. Although we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

8. Where do we transfer and store information?

Tradewater is based in the United States, and any information transmitted to us may be stored, accessed, or processed in the United States. Residents of some other countries, including residents of the European Union, should be aware that the laws of the United States do not offer the same protections as the laws of your home country.

Users located in the European Union should note that their information may be transferred to the United States, whose laws may be deemed inadequate by European Union member State standards. Users of the Website located outside of the United States hereby consent to the collection, use and dissemination of any and all information, including personal information, in accordance with this policy and the related Terms of Use, and further consent to such information being transferred to and/or stored in the United States.

9. Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on our Website. We do not knowingly collect personal information from children under 13 or knowingly allow such persons to log in our Website. If you are under 13, do not use or provide any information on this Website or on or through any of their features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of our Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the details specified in the “Contact Information” section below.

10. Changes to Our Privacy Policy

We will post any changes we make to our privacy policy on this page. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes. Please review the changes carefully. If you do not agree to any of the changes, you should stop using our Website. Unless stated otherwise, our current policy applies to all information that we have about you and your account. Using the Website after a notice of changes has been communicated to you or published on our Website will mean that you have consented to the changed terms or practices.

11. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Data Collection Officer:         Senior Associate of Verification

1411 W. Carroll Street, Unit N

Chicago, IL 60607

312-273-5122

info@tradewater.us (Subject Line: “Data Collection Officer”)

Permanence

Emission reductions are considered permanent if they are not reversible. In some projects, such as forestry or soil preservation, carbon offset credits are issued based upon the volume of CO2 that will be sequestered over future decades—but human actions and natural processes such as forest fires, disease, and soil tillage can disrupt those projects. When that happens, the emission reductions claimed by the project are reversed.

The destruction of halocarbon does not carry this risk. All destruction activities in Tradewater’s projects are conducted pursuant to the Montreal Protocol , which requires “a destruction process” that “results in the permanent transformation, or decomposition of all or a significant portion of such substances.” Specifically, the destruction facilities Tradewater uses must meet or exceed the recommendations of the UN Technology & Economic Assessment Panel , which approves certain technologies to destroy halocarbons, including the requirement that the technology achieve a 99.99% or higher “destruction and removal efficiency.” Simply put, this means that Tradewater’s technologies ensure that over 99.99% of the chemicals are permanently destroyed. During the destruction process, a continuous emission monitoring system is used to ensure full destruction of the ODS collected.

Accuracy

Some carbon offset projects necessarily rely on estimations or assumptions when calculating the emission reductions from project activities. Forestry projects, where developers make assumptions about the carbon that will be sequestered over future decades if trees are conserved, are a perfect example. Such projects sometimes result in an overestimation of the environmental benefit of the project.

Tradewater’s halocarbon projects avoid the issue of overestimation by consistently conducting extremely precise testing and measurement of the amount of refrigerant destroyed in each project.

  • Every container of ODS that Tradewater destroys is weighed by a third-party using regularly calibrated scales. The ODS is then sampled by a third-party and analyzed by an accredited refrigerant laboratory to determine its species and purity. These two steps combine to ensure that credits are issued only for the precise volume and type of refrigerant destroyed.
  • The destruction facilities that Tradewater uses continuously monitor the incineration process during destruction events to ensure that over 99.99% of the ODS is destroyed. This monitoring is mandated by regulatory protocols and is part of the verification process to which projects are subjected.
  • Tradewater accounts for the project emissions created during the collection, transport, and destruction of ODS, and the number of offsets issued is reduced by a corresponding amount. The protocols that we use also build in other reductions to account for substitute chemicals that will be used to replace the destroyed refrigerants. Tradewater publishes this information in the documentation for all its ODS destruction projects. These documents outline how the material was obtained, the project emissions calculations, the test results, and the amount and type of ODS chemicals destroyed, among other information.

    • Additionality

    It is a basic requirement of all carbon offset projects that the underlying project activities are additional. “Additional” means that the projects would not happen in the absence of a carbon market. Tradewater’s halocarbon projects simply would not happen – and the gases would be left to escape into the atmosphere – without the sale of the resulting carbon offset credits. This is because there is no mandate to collect and destroy these gases. It is still permissible to buy, sell, and use halocarbons that were produced before the ban. There are other reasons halocarbon destruction projects are additional:

    • There are no incentives or financial mechanisms to encourage halocarbon destruction. According to the International Energy Agency and United Nations Environment Program, “there is rarely funding nor incentive” to recover and destroy ozone depleting substances in storage tanks and discarded equipment. And collecting, transporting, and destroying halocarbons is time-intensive and expensive. The burden to collect and destroy these gases therefore remains prohibitive outside of carbon offset markets—meaning that if organizations like Tradewater do not do this work, nobody else will.
    • Countries are not focused on the need to collect and destroy halocarbons. The Montreal Protocol has been celebrated as a success because of its production ban. This success, however, ignores the legacy gases produced before the ban and is a blind spot for government regulators. In the U.S., for example, the Environmental Protection Agency (EPA) developed a Vintaging Model in the 1990s to estimate the quantify of ozone depleting substances left in circulation. Based on the inputs and assumptions put into the model, the EPA predicted that no CFCs would be available for recovery beyond 2020 in the United States. But this prediction did not prove accurate. Tradewater has collected and destroyed more than 1.5 million pounds of CFCs globally in recent years and continues to identify thousands of pounds per week.
    • International carbon accounting standards do not require corporations to measure or track emissions tied to halocarbons, and refrigerants are specifically excluded from Science Based Targets initiative (SBTi) commitments. These commitments derive from emissions reporting under the GHG Protocol, which requires companies to report on emissions only from new generation refrigerants, such as hydrofluorocarbons (HFCs), but does not establish any obligation to report inventories or emissions of refrigerants still in use, such as CFCs and HCFCs. All these factors combine to make Tradewater’s carbon offset projects highly additional. As Giving Green, an initiative of IDinsight, concluded: “Tradewater would not exist without the offset market, so this element of additionality is clearly achieved.” The case for additionality is not so clear for some other project types, such as forestry and landfill gas carbon projects. For example, some forests are already being conserved for their beauty, or for use as parks, and generate carbon offset credits only because those conservation efforts do not yet have full formal protection in place to avoid deforestation in the future. Similarly, methane from landfills can be used to make electricity or captured as compressed natural gas, thereby creating additional revenue streams to support the activities, beyond the sale of carbon credits.