Privacy Policy

This policy describes how BTR Prime processes information to support cooperation under Article 6 and reporting under Article 13’s Enhanced Transparency Framework (ETF), including the Article 6 Readiness Tracker and related services. The programme is supported by CACE and ClimatePoint.

Last updated: 29 August 2025

Who we are.
Controller
BTR Prime (“we”, “us”, “our”). Single contact point for rights requests: partners@btrprime.com
Programme supporters
CACE and ClimatePoint support the programme. For specific programme-level activities (e.g., preparing briefs, coordination with public entities), they may act as joint controllers with BTR Prime or as independent controllers—see “Joint controllership summary” and “How we share information”.
Scope
This policy covers BTRprime.com, the Readiness Tracker, the standalone Quick Assessment, emails to partners@btrprime.com, and related communications.
UNFCCC context: we work with sovereign institutions (“Parties” and their designated entities) to help organize information for BTRs. Decisions remain sovereign.

At a glance

  • What we collect: contact/professional details, assessment inputs, programme correspondence, minimal logs, and essential cookies.
  • Why: to operate the Readiness Tracker, coordinate Article 6 work, and keep systems secure.
  • Who sees data: BTR Prime, and where relevant, CACE/ClimatePoint and service providers under DPAs.
  • Where stored: primarily EEA/UK; international transfers use SCCs or similar safeguards.
  • How long: aligned to BTR/ETF cadence (see retention table).
  • Your rights: access, rectify, erase, object/restrict, portability, and complaint routes.

UNFCCC context and terminology

References to Articles 6 and 13 (ETF) are to the Paris Agreement and its modalities, procedures and guidelines. Terms such as “authorization”, “corresponding adjustment”, “inventory (CRTs)”, and “NDC/support tables (CTFs)” are used in their normal UNFCCC sense for information management and reporting support.

Information we collect

  • Contact and professional details — name, title, organisation, country, email, phone (if provided).
  • Assessment inputs — answers provided for a country readiness check, derived score/band, comments.
  • Programme correspondence — emails and scheduling notes when you interact with the programme.
  • Usage and device data — basic hosting logs (IP address, user agent, pages, timestamps) and aggregated analytics where implemented.
  • Cookies/local storage — essential features (e.g., navigation state). No third-party advertising cookies.
  • Public and partner sources — contact points for institutions (e.g., DNAs), from public notices or provided by programme partners for coordination.

How we use information

  • Provide the service — operate the Readiness Tracker, generate readiness briefs, and respond to requests.
  • Programme operations — coordinate calendars with ministries, designated national authorities (DNAs), validators and relevant stakeholders.
  • Support and communications — respond to inquiries, schedule meetings, and send updates you request.
  • Improvement and safety — maintain, secure and improve our site and processes; prevent abuse; troubleshoot.
  • Compliance — meet legal obligations and respond to lawful requests by competent authorities.

Legal bases (EU/UK GDPR)

  • Legitimate interests — operate and secure the site; evaluate country readiness; send requested briefs and coordination notices.
  • Contractual necessity — to take steps at your request in anticipation of an engagement.
  • Consent — when you submit an assessment and consent to contact; for optional analytics or newsletters (if enabled).
  • Legal obligation — to comply with applicable laws and lawful requests.

Legitimate interests test (summary)

  • Interest: programme coordination, readiness evaluation, site security.
  • Necessity: limited personal data needed to identify contacts and deliver requested outputs.
  • Safeguards: minimisation, role-based access, short log retention, opt-outs where applicable.

Joint controllership summary (GDPR Art. 26)

ActivityController rolePrimary contact for rights
Programme-level briefs; coordination with public entities BTR Prime, CACE, ClimatePoint act as joint controllers partners@btrprime.com (we coordinate resolution across parties)
Platform operation, hosting, site security BTR Prime as controller; vendors as processors
Independent outreach by supporters CACE/ClimatePoint may act as independent controllers for compatible purposes

You may contact any controller. We agree to cooperate and ensure you can exercise your rights consistently via the single address above.

How we share information

  • Programme supporters (CACE and ClimatePoint) — For specific activities (e.g., preparing briefs, policy coordination, outreach), we may share your submission and contact details as described above.
  • Service providers (processors) — reputable vendors for hosting, email, collaboration and infrastructure under data-processing agreements.
  • Public authorities — when legally required or to protect rights, safety and programme integrity.
  • Business changes — in a merger, acquisition or reorganisation, data may transfer to a successor subject to this policy.

International transfers

We may process data outside your country. Where required, we use safeguards such as EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum. Typical processor locations: EEA, UK, and the United States (with SCCs).

Retention and BTR cycles

Retention reflects ETF reporting cadence. Unless otherwise required, we keep:

CategoryTypical retentionReason
Assessment submissions and briefs24 months from last interaction, or for the duration of an active engagement; earlier deletion on request.Maintain continuity through the BTR drafting window.
Programme correspondenceUp to 36 months for auditability and follow-up; earlier deletion on request unless legally required.Audit trail for coordination and validator lane.
Logs and security data90 days (rolling), unless required for investigations.Security and abuse prevention with minimal footprint.
Contractual records (if any)As required by law (typically 6–10 years).Statutory compliance.

Confidentiality and classifications

We recognise sovereign information handling. Materials may be marked, for example, “Public”, “Official Use”, “Confidential” or “Restricted” by the providing authority. We honour such markings and limit access accordingly. Where Article 6 requires public information, we publish accordingly; where confidentiality applies, we restrict access and honor sovereign markings.

Public Official Use Confidential Restricted

Security and breach notifications

We apply appropriate technical and organisational measures (encryption in transit, access controls, least-privilege, vendor DPAs, audit trails). If we detect a personal-data breach posing risk, we will notify the relevant authority within required statutory timelines and inform affected individuals as required. Security contact: partners@btrprime.com.

Your rights

If you are in the EEA/UK (or where similar rights apply), you may request:

  • Access to your personal data;
  • Rectification of inaccurate or incomplete data;
  • Erasure (“right to be forgotten”);
  • Restriction or objection to certain processing;
  • Portability of data you provided;
  • Withdrawal of consent where processing relies on consent.

To exercise rights, email partners@btrprime.com or use the rights-request form below. You may also contact partners@btrprime.com and partners@btrprime.com for activities they control. We aim to respond within one month or as required by law.

Lead supervisory authority

Our lead EU/EEA supervisory authority is the Norwegian Data Protection Authority (Datatilsynet). You may lodge a complaint with Datatilsynet or your local authority.

US state privacy notices

We are a B2B programme and do not sell personal information or use it for cross-context behavioural advertising. Where state laws (e.g., California, Colorado, Virginia, Connecticut) apply, you may request access, correction or deletion as above. We do not knowingly collect personal data from minors.

Cookies and local storage

You can adjust non-essential cookies anytime:

CategoryPurposeProviderDataRetentionOpt-out
Essential Core site functionality (navigation, basic session, security) First-party Session ID, preference flags Session or until cleared Via your browser
Analytics (optional) Understand page usage to improve UX (when enabled) None active Aggregated usage metrics See provider policy (if enabled) Respect banner choices; disable anytime via the button above

Automated decisions / special-category data

We do not use automated decision-making with legal or similarly significant effects. Please do not submit special-category data unless we explicitly request it on a valid legal basis.

Children

Our services are not directed to children under 16, and we do not knowingly collect their personal data. If you believe a child has provided data, please contact us to remove it.

Changes to this policy

We may update this policy to reflect legal or programme changes. We will revise the “Last updated” date and, where appropriate, notify you.

Contact

BTR Prime
Email: partners@btrprime.com
Address: 123 Example St, City, Country
CACE
Email: partners@btrprime.com
Address: Qatar Science and Technology Park, Gharaffa, Doha, Qatar
ClimatePoint
Email: partners@btrprime.com
Address: Universitetsgata 12, 0164 Oslo, Norway
Org.no: 929 099 389
Data Protection Officer
If appointed, contact: partners@btrprime.com

Rights-request form

This lightweight form prepares an email to partners@btrprime.com. No data is sent until you hit “Create email”.

Your name
Your email
Request type
Scope or details

Programme-specific notes

  • Assessment emails: When you submit the Quick Assessment, your inputs are assembled into a plain-text email to partners@btrprime.com. We process it in our email systems and share with CACE/ClimatePoint as needed to prepare and deliver your country brief.
  • Evidence references: Briefs reference public or ministry-provided documents. Briefs are for programme coordination and are not public disclosures unless expressly agreed by the providing authority.
  • DPAs/SCCs: Standard data-processing terms are available on request.