Legal · Last updated: November 12, 2026
Privacy Policy.
Data controller
Environmental Markets Fairness Foundation (EMFF), a foundation under Swiss law, UID CHE-314.480.783, with its registered office at Zürcherhof, Limmatquai 4, 8001 Zurich (Switzerland) and email address info [arroba] efairmarkets.earth, is the controller of the personal data processed in connection with this website, unless expressly stated otherwise.
EMFF applies the Swiss Federal Act on Data Protection (FADP). Regulation (EU) 2016/679 (GDPR) and other European Union rules apply to processing that actually falls within their territorial and material scope. The fact that the website can be accessed from the EU or is hosted in Spain does not, by itself, make the GDPR apply generally to all of EMFF’s activities.
Personal data we may process
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Contact and inquiry data: first and last name, organization, job title, email address, phone number, country, reason for contact and message content, depending on the fields actually enabled.
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Newsletter subscription data: first and last name, organization, country and email address.
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Professional relationship data: communications and data needed to manage partnerships or institutional requests.
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Necessary technical data: IP address, date and time of access, requested URL, browser type and security information or server logs, when generated by the infrastructure.
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Analytics data: online identifiers and browsing events processed through Google Analytics, only if the user accepts analytics cookies.
We do not deliberately request special categories of personal data through the website. Please do not include particularly sensitive information in your messages unless it is essential. No decisions based solely on automated processing that produce legal or similarly significant effects on users are made.
Purposes and grounds for processing
| Purpose | Grounds and conditions |
|---|---|
| Responding to inquiries or requests | Legitimate interest in handling the communications received; where applicable, steps prior to entering into a contract. Consent will be considered only where it is the appropriate basis. |
| Managing relationships with organizations and partners | Legitimate interest, performance of agreements or compliance with obligations, depending on the nature of the relationship. |
| Technical operation and protection of the website | Legitimate interest in maintaining availability and security; compliance with legal obligations where applicable. |
| Non-essential web analytics | Prior consent where required; users may withdraw it through the preferences manager. |
| Sending the newsletter to subscribers | Consent of the subscriber, given by checking the box on the subscription form. It may be withdrawn at any time through the “Unsubscribe” link included in each mailing or by writing to info [arroba] efairmarkets.earth. |
| Legal obligations and defense of rights | Compliance with legal obligations and legitimate interest in documenting, establishing or defending claims. |
Where the GDPR applies, the corresponding legal bases are interpreted in accordance with Article 6 GDPR. Under the Swiss FADP, processing is carried out in accordance with the principles of lawfulness, good faith, proportionality, purpose limitation and transparency; whether specific consent is required is assessed for each processing activity.
The purpose of the newsletter is to send EMFF news, event announcements and other communications considered relevant to subscribers. Subscription requests arrive at info [arroba] efairmarkets.earth, and the EMFF team manually adds each person to its contact list, from which the newsletter is sent with recipients in blind copy (BCC). The “Unsubscribe” link in each mailing leads to a Google form; when the request is received, the EMFF team manually removes the contact from the list. Subscribers may also unsubscribe by writing to info [arroba] efairmarkets.earth.
Data retention
Inquiries received through the form or by email will be kept for as long as needed to handle them and, as an operating rule set by EMFF, for up to twelve months after they are resolved, unless there is a subsequent relationship, a legal obligation or a documented need to keep them longer. Copies of form messages stored in the website’s database are automatically deleted 90 days after they are received.
Newsletter subscription data will be kept in EMFF’s contact list for as long as the person remains subscribed and will be deleted when the unsubscribe request is processed, unless it must be kept to prove consent or to comply with a legal obligation.
Information related to projects, agreements and partners will be kept for the duration of the relationship and afterwards in accordance with applicable periods and justified needs. Technical server logs are kept for 30 days. Cookie retention periods are set out in the Cookie Policy.
Recipients, providers and hosting
To operate the website, EMFF relies on a development and maintenance agency and on web hosting services located in Spain. EMFF’s email provider (Google Workspace) is also involved: it receives form messages and subscription requests at info [arroba] efairmarkets.earth, holds the newsletter contact list, sends the newsletter and hosts the unsubscribe form (Google Forms). Google Analytics and Google Tag Manager are involved only if the user accepts analytics cookies. EMFF will share data with these recipients only when necessary for the stated purposes and in accordance with the applicable contractual terms and security measures.
The efairmarkets.earth website is hosted by Click Naranja, S.L., tax ID B84120666, with its registered office at Glorieta de Quevedo, 9, 2.º D, 28015 Madrid, Spain (www.clicknaranja.com · hola@clicknaranja.com). Click Naranja provides the hosting service to Environmental Markets Fairness Foundation. To do so, it uses Arsys Internet, S.L.U. as a subprovider, tax ID B85294916, with its registered office at Calle Madre de Dios, 21, 26004 Logroño (La Rioja), Spain (www.arsys.es), part of the IONOS group. The servers are located in Spain, at Arsys’s data center in Logroño (La Rioja). Email notifications of form submissions are sent to EMFF through Click Naranja’s email service. Daily backups of the hosting account are stored in Dropbox (Dropbox International Unlimited Company), which Click Naranja also uses as a subprovider.
Where these providers act as processors, EMFF will verify that the relevant contractual agreements are in place, along with guarantees of confidentiality, security and subcontracting, and mechanisms for assistance, return and deletion of data. EMFF does not sell personal data obtained through the website.
Members of the EMFF team based in Argentina access the messages received through the forms and by email in order to handle them. Argentina has a level of data protection recognized as adequate by Switzerland and the European Union. Other independent contractors working with EMFF from Spain, Argentina or Brazil do not access visitors’ personal data simply because they work with EMFF.
International transfers
Because the website is hosted in Spain, technical data and, where applicable, form data may be processed there. Spain is recognized as providing an adequate level of data protection under Swiss law. The same applies to Argentina, from where messages are handled (see section 5). If data is disclosed to other countries, EMFF will state the destination countries and the applicable safeguards, in accordance with Article 19(4) of the Swiss FADP and, where applicable, the GDPR.
Google services (Google Workspace and, only if the user accepts analytics cookies, Google Analytics and Google Tag Manager) may involve processing outside Switzerland and the European Economic Area, including in the United States. Google LLC is certified under the Swiss–U.S. Data Privacy Framework and the EU–U.S. Data Privacy Framework, on which these transfers rely. For other recipients outside those countries, a valid mechanism will be required, such as standard contractual clauses and supplementary measures where appropriate.
Backups of the hosting account are stored in Dropbox, on servers in the United States. This transfer also relies on the Swiss–U.S. Data Privacy Framework and the EU–U.S. Data Privacy Framework, under which Dropbox, Inc. is certified.
Data subject rights
Under the Swiss FADP, individuals may exercise their rights to information and access and, where applicable, the rights to rectification, erasure or objection, as well as other rights provided by law. Where the GDPR applies to a processing activity, the rights granted by that Regulation may also be exercised, including, as the case may be, restriction of processing, data portability and withdrawal of consent.
You may exercise your rights and send any questions to info [arroba] efairmarkets.earth. EMFF may request only the information needed to verify your identity where appropriate. Under Swiss law, access requests are generally answered within 30 days; where the GDPR applies, the time limits and conditions set out in that Regulation will be observed (generally one month).
In Switzerland, the competent federal data protection authority is the Federal Data Protection and Information Commissioner (FDPIC/EDÖB): www.edoeb.admin.ch. Where the GDPR applies to a processing activity, the data subject may lodge a complaint with the competent European supervisory authority in accordance with that Regulation. This information does not exclude other legal remedies.
Social media and videos
EMFF publishes links to its LinkedIn and YouTube profiles, which open on those platforms and do not set cookies through this website. The website’s videos are hosted on its own server and are not loaded from YouTube. When users visit third-party platforms, their data is governed by those services’ policies.
Security
EMFF applies technical and organizational measures appropriate to the risk, including access control, provider management and security measures for the server and forms. No system connected to the internet can guarantee zero risk. Security incidents will be handled in accordance with the applicable notification obligations.
Minors and changes
The website is aimed mainly at a professional and institutional audience and is not designed to deliberately collect data from minors. If unauthorized processing is detected, the necessary deletion and protection measures will be assessed in accordance with applicable law.
EMFF will update this policy when the purposes, providers, measurement tools or applicable law change. The current version will always be available on the website.