Legal · Compliance · Data

Privacy Policy &
Terms of Service

Carbon Architecture Advisory Services · Nairobi, Kenya
Effective date: 1 January 2025 · Last updated: March 2026
These documents govern use of the Article 6 Investment Readiness Index tool and all related services provided by Carbon Architecture Advisory Services.
Part I · Privacy Policy
01
About Us

Carbon Architecture Advisory Services ("CAAS", "we", "us", "our") is a specialist advisory firm providing Article 6 carbon market intelligence and project readiness services. We are based in Nairobi, Kenya, and operate primarily through digital tools and advisory engagements.

Our primary contact for all privacy and data matters is Karen Too. Contact details are at the end of this document.

This Privacy Policy applies to personal data collected through the Article 6 Investment Readiness Index tool ("the Tool") and any related correspondence or services.

02
What Data We Collect

We collect the following personal data when you purchase a full report through the Tool:

Identity Data
Your full name, as entered at the payment gate.
Contact Data
Your email address, used to deliver your payment receipt and for follow-up correspondence if requested.
Professional Data
Your organisation name and professional role, provided optionally to help us understand our user base and improve the Tool.
Transaction Data
Payment reference number, currency, amount, and timestamp. We do not store card numbers, bank account details, or any payment instrument data. These are handled exclusively by Paystack.
Assessment Data
The country, sector, project stage, and assessment scores you enter into the Tool. This data is processed locally in your browser and is not transmitted to our servers. It is included in the report generated for you and in the payment notification email sent to CAAS for internal record-keeping only.
No cookies or tracking The Tool does not use cookies, analytics trackers, advertising pixels, or any third-party tracking technology. No usage data is collected passively.
03
How We Use Your Data

We process your personal data on the following lawful bases under the Kenya Data Protection Act 2019 and, where applicable, the EU General Data Protection Regulation (GDPR):

Contract Performance
To deliver the full report you have purchased, issue a payment receipt, and fulfil our obligations as a digital services provider.
Legitimate Interest
To maintain internal records of transactions for financial and operational purposes; to understand aggregate demand by sector and role in order to improve the Tool.
Legal Obligation
To comply with financial record-keeping requirements under Kenyan law, including the Tax Procedures Act 2015.
Consent
Where you have explicitly consented (by ticking the acknowledgement checkbox at the payment gate) to the processing described in this policy.

We do not use your personal data for automated decision-making, profiling, or any purpose unrelated to the services described above. We do not send unsolicited marketing communications.

04
Payment Processing

All payments are processed by Paystack (Paystack Inc., a subsidiary of Stripe, Inc.). When you complete a payment, you are subject to Paystack's own privacy policy and terms of service, available at paystack.com/privacy.

CAAS receives a payment confirmation from Paystack containing your name, email address, payment reference, amount, and currency. CAAS does not receive, store, or have access to your card number, bank account details, or any other payment instrument data.

Paystack is PCI-DSS Level 1 certified. All payment data is encrypted in transit and at rest within Paystack's systems.

05
Data Sharing

We do not sell, rent, trade, or otherwise transfer your personal data to third parties, with the following limited exceptions:

Paystack
Your name and email address are shared with Paystack solely to process your payment transaction. Paystack acts as a data processor on our behalf under its own data processing agreement.
Legal Requirements
We may disclose your data if required to do so by law, court order, or regulatory authority, or where we believe disclosure is necessary to protect the rights, property, or safety of CAAS, our users, or the public.
Business Transfers
In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity, subject to the same privacy protections described in this policy.
06
Data Retention

We retain your personal data for three (3) years from the date of your transaction. This retention period reflects our financial record-keeping obligations under Kenyan law and our legitimate interest in maintaining transaction records for dispute resolution purposes.

Assessment data (your Tool responses, scores, country, and sector selections) is included in the payment notification email and retained as part of that record for the same three-year period. It is not stored in any separate database.

After the retention period, all personal data is permanently deleted from our records. You may request earlier deletion — see Your Rights below.

07
Your Rights

Under the Kenya Data Protection Act 2019 and, where applicable, the GDPR, you have the following rights in relation to your personal data:

Right of Access
To request a copy of the personal data we hold about you.
Right to Rectification
To request correction of any inaccurate or incomplete personal data.
Right to Erasure
To request deletion of your personal data, subject to our legal record-keeping obligations.
Right to Restrict Processing
To request that we limit the processing of your personal data in certain circumstances.
Right to Data Portability
To receive your personal data in a structured, commonly used format.
Right to Object
To object to processing carried out on the basis of legitimate interest.
Right to Withdraw Consent
Where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at karen.too@outlook.com with the subject line "Data Rights Request." We will respond within 21 days. There is no charge for a first request. If you are unsatisfied with our response, you may lodge a complaint with the Office of the Data Protection Commissioner of Kenya (odpc.go.ke).

Part II · Terms of Service
08
Terms of Service

By accessing or using the Article 6 Investment Readiness Index Tool ("the Tool"), you agree to these Terms of Service. If you do not agree, do not use the Tool.

Nature of the Service
The Tool provides a structured analytical framework for evaluating Article 6 carbon project readiness. It is an orientation and decision-support instrument. It is not legal advice, financial advice, investment advice, or a guarantee of any outcome. Authorization probability figures are specialist judgement assessments based on publicly available data and are not actuarial or legally binding assessments.
No Professional Relationship
Use of the Tool does not create a client relationship, advisory relationship, or any form of professional engagement between you and Carbon Architecture Advisory Services. Such a relationship can only be established through a separate written engagement agreement.
Limitation of Liability
Carbon Architecture Advisory Services accepts no liability for any loss, damage, or adverse outcome arising from reliance on the Tool's outputs, scores, pathway recommendations, authorization probability indicators, or revenue model projections. You use the Tool and its outputs entirely at your own risk. Our total liability to you in connection with the Tool shall not exceed the amount you paid for access.
Payment and Delivery
The full report is a digital product delivered instantly in your browser upon payment confirmation. Payment is processed by Paystack. Refunds are not available after report delivery. If your report was not delivered following a confirmed payment, contact karen.too@outlook.com within 24 hours with your Paystack reference number.
Permitted Use
You may use the Tool and the report generated for your own internal professional purposes. You may share the report with colleagues, co-investors, lenders, or counterparties as part of your project or investment process. You may not resell, sublicense, or commercially redistribute the report or any part of it without written permission from Carbon Architecture Advisory Services.
Accuracy and Currency of Data
Jurisdiction data, authorization probability figures, and sector benchmarks are based on publicly available UNFCCC records and bilateral transaction data as of Q1 2026. Article 6 policy environments evolve rapidly. CAAS makes no warranty that the data remains current at the time of your use. You are responsible for verifying country-specific details directly with the relevant host Ministry, DNA, or legal advisor before making any commitment.
Availability
We do not guarantee uninterrupted or error-free access to the Tool. We reserve the right to modify, suspend, or discontinue the Tool at any time without notice. Where pre-payment access is interrupted, we will endeavour to provide a refund.
Governing Law
These Terms are governed by the laws of Kenya. Any dispute arising from use of the Tool shall be subject to the exclusive jurisdiction of the courts of Nairobi, Kenya.
Changes to These Terms
We may update these Terms and the Privacy Policy at any time. The current version is always available at this URL. Continued use of the Tool after any update constitutes acceptance of the revised terms.
09
Intellectual Property

The Article 6 Investment Readiness Index, including its scoring framework, question set, gap analysis logic, jurisdiction data, role calibration system, and all associated content, is the original intellectual property of Carbon Architecture Advisory Services.

Copyright in the Tool and its content is registered with the Kenya Copyright Board. All rights are reserved. Reproduction, redistribution, reverse-engineering, or derivative use of any part of the Tool — including its scoring methodology, question architecture, country data, or action plan content — without prior written permission from Carbon Architecture Advisory Services is prohibited and may constitute infringement under the Kenya Copyright Act 2001.

The underlying Article 6 framework (UNFCCC Decisions, NDC structure, LoA and CA requirements, PACM Supervisory Body rules) is in the public domain. The CAAS implementation, weighting, scoring architecture, advisory content, and jurisdiction intelligence built on that framework are proprietary.

10
Contact

For all privacy enquiries, data rights requests, legal questions, or service issues, contact:

Carbon Architecture Advisory Services
Karen Too
Nairobi, Kenya

Email: karen.too@outlook.com
Subject line for privacy matters: "Data Rights Request — A6IRI"
Subject line for legal matters: "Legal Enquiry — A6IRI"

We aim to respond to all enquiries within 2 business days and to data rights requests within 21 days.