Privacy Policy
Last updated: March 2, 2026
This Privacy Policy explains how personal data may be processed when you use Klima Protocol websites and any related verification-gated features. Most Klima Protocol activity is on-chain and therefore public by design.
1) Who we are
Controller: Klima Fintech Ltd.
Contact: privacy@klimaprotocol.com
2) What this policy covers
This policy covers:
- Website / off-chain interactions (e.g., pages you visit, forms you submit, support communications).
- On-chain activity (e.g., wallet addresses and transactions recorded on public blockchains).
- Identity verification (KYC), where used via zkMe, and the resulting verification outcome and gating status we maintain.
This policy does not replace third-party policies for vendors you interact with directly (e.g., zkMe). Where relevant, we link to those resources.
3) Key concept: on-chain data is public and persistent
When you interact with Klima Protocol smart contracts, the blockchain will record information such as:
- Wallet address
- Transactions and interaction history
- Token balances (depending on chain mechanics)
This information:
- Is publicly visible
- Is not controlled by Klima Fintech Ltd.
4) Identity verification (KYC) via zkMe
4.1 When verification is used
Some features may require verification to align with market integrity, counterparty requirements, or risk controls that the ecosystem chooses to apply (for example, to reduce fraud/abuse or meet expectations of certain carbon market participants).
4.2 Roles
Klima Fintech Ltd.: controller for the limited verification result data we maintain (see below).
zkMe: processes identity verification inputs (documents, liveness checks, screening) within their systems.
Learn more: zkMe documentation
4.3 What happens in verification flows
zkMe may perform (depending on configuration):
- document validation
- liveness checks
- screening checks (e.g., sanctions/PEP)
- eligibility checks (e.g., age or country parameters)
What we receive from zkMe:
- Verification outcome (e.g., pass / flag)
- Verification reference (e.g., verification ID and timestamp)
- Wallet address used for gating
- Proof / gating status (e.g., whether a proof/attestation is present and recognized)
- Email address
- Citizenship status
We do not store any of this information in our own systems; it is held within the zkMe platform.
What we do not have access to:
- Document images
- Raw biometric data
- Full document numbers
4.4 Wallet address sharing clarification
To enable verification-gated access and (where applicable) minting/association of a non-transferable proof, zkMe must be able to associate a verification result to a wallet address. Depending on implementation, this may occur because:
- you provide the wallet address during the zkMe flow, and/or
- we transmit the wallet address to zkMe for the purpose of completing verification association or proof minting.
In all cases, the wallet address is the only identifier we expect to share for this purpose, and we do not send identity documents to zkMe.
5) Access gating proof (on-chain)
After successful verification, a non-transferable on-chain proof/attestation may be minted or referenced for gating.
This proof/attestation:
- is designed to contain no “raw” personal identity data (e.g., it may reflect boolean or threshold flags such as “passed verification” and optional eligibility thresholds)
- is public and may be difficult or impossible to erase due to blockchain properties
- is used to gate access to certain features
Choose a wallet you are comfortable associating with this proof/attestation.
We may revoke gating or require re-verification if risk changes (e.g., policy updates, suspected fraud, sanctions list updates, or integrity concerns).
6) Website contact forms & off-chain communications
If you contact Klima Protocol via a website form:
- the form data is processed by Carbonmark DMCC
- Carbonmark acts as controller for that form submission data under its own policy
- Carbonmark’s privacy policy: https://www.carbonmark.com/privacy-policy
Typical form data may include:
- Name
- Email address
- Organization name
- Message content
This data is used to respond to your enquiry and manage follow-up communications directly related to that enquiry. Where you opt in, contact details may be used to send updates; you can unsubscribe at any time.
7) Cookies & analytics
The website may use:
- Essential cookies (site functionality)
- Analytics / session tools (e.g., Lucky Orange)
- Standard traffic analytics
These tools may collect:
- IP address (or partial IP depending on configuration)
- Browser type / device info
- Pages visited
- Interaction data (e.g., clicks, scroll)
We use analytics to:
- Improve usability and performance
- Understand general traffic patterns
- Protect the site from abuse and diagnose issues
We do not use analytics for advertising profiling.
Where required by law, we provide a cookie consent mechanism.
8) Purposes and legal bases (GDPR/UK GDPR, where applicable)
Where GDPR/UK GDPR applies, we process limited personal data for:
- Security and abuse prevention (e.g., protecting services, investigating suspicious activity)
Legal basis: legitimate interests - Site analytics and product improvement
Legal basis: legitimate interests (and consent where required for cookies/trackers) - Responding to enquiries (where you contact us)
Legal basis: legitimate interests (and/or steps requested by you prior to a potential relationship) - Verification-gated access (where verification is used)
Legal basis: legitimate interests (protecting integrity, reducing abuse, aligning with counterparty expectations)
9) Sharing and disclosures
We do not sell personal data.
We may share limited data as follows:
9.1 zkMe (verification vendor)
zkMe processes identity verification inputs within zkMe systems. We receive and store only the limited outcomes/references described above. zkMe may use sub-processors; refer to zkMe’s published materials for details.
9.2 Service providers (security/audit)
We may use service providers for security monitoring, auditing, incident response, or infrastructure. Where used, access is limited and subject to contractual and technical safeguards. Data involved is expected to be limited to items like wallet addresses, timestamps, and security logs.
9.3 Authorities / regulators
Only where required by law or upon lawful request, we may disclose information we hold. In practice, this is expected to be limited to wallet addresses and gating/verification status metadata (not identity documents, which we do not hold).
10) Data retention
10.1 On-chain
On-chain records are retained according to blockchain characteristics and are not controlled by us.
10.2 In our systems (off-chain)
Verification data (including email address and citizenship status) is held within the zkMe platform and is not stored in Klima's own systems. Refer to zkMe's terms and policies for their retention practices.
We may maintain a wallet-address-to-gating-status mapping for the purpose of operating verification-gated access controls, audit, and abuse prevention.
10.3 zkMe retention
zkMe’s retention and deletion practices are controlled by zkMe. Refer to zkMe’s terms/policies for how long they retain verification inputs and what deletion options exist.
11) Your rights
Subject to applicable law, you may request:
- Access to personal data we hold about you
- Rectification (where applicable)
- Restriction or objection (where applicable)
- Portability (where applicable)
- Erasure (where legally possible)
Notes (important limitations)
- On-chain data cannot be deleted or modified by us.
- zkMe’s retention rules may limit or delay erasure of data held by zkMe.
- Where we rely on legitimate interests, you may object, and we will assess your request.
- If you request erasure of the data we maintain for gating, the practical effect is that we can remove your wallet address and associated pass/flag status from our allowlist / gating records. If removed, that wallet will not be able to access verification-gated features unless it completes verification again through zkMe.
- Refer to zkMe’s terms of use and privacy materials for their retention and erasure terms.
To exercise rights: privacy@klimaprotocol.com and include the wallet address(es) relevant to your request.
You may also have the right to complain to your local supervisory authority where applicable.
12) International transfers
Blockchain infrastructure is global by design.
For off-chain processing, vendors (including zkMe) and infrastructure providers may process data in multiple jurisdictions. Where required, appropriate safeguards are used (e.g., SCCs/IDTA/adequacy decisions). You can request more detail via privacy@klimaprotocol.com.
13) Security
We apply reasonable technical and organizational measures appropriate to the limited off-chain data we process. Measures may include controls such as encryption in transit, access controls, logging/monitoring, and vendor management. Blockchain security is governed by the underlying networks and your wallet provider.
14) Children
Klima Protocol services described here are intended for individuals 18+. We do not knowingly verify minors.
15) Changes to this policy
We may update this policy from time to time. The “Last updated” date will change, and material updates will be posted on this page.
