Effective date: October 24, 2023
What information do we collect?
“Personal Information” is personal information you provide us, or what we collect from you and your devices in connection with your access to and use of the Services. In legal terms, we collect and use this Personal Information as a data controller. There are two general ways in which we collect Personal Information when you access or use the Services.
1. Information we automatically collect from your use of the Services – When you visit the Services, your browser and computer automatically provide to us certain technical information about your computer or device. This information may be collected using “cookies”, “log files” web beacons”, “tags” and “pixels”. The following are different kinds of information we automatically collect from your use of the Services:
2. Information you give us – When you fill out a form, send an email to our team or otherwise send us information through the Services, we collect personal information about you. The Services have webpages that allow you to submit a variety of personal information to us. The following are different kinds of information you give us from your use of the Services
a. “Identity Information” – includes your first name, middle name, last name, title and other corresponding identification information.
b. “Contact Information” – includes your email address and telephone number.
c. “Professional Information” – which includes your job title, previous positions and professional experience, email address and phone number.
d. “Enquiry Information” – includes information contained in any enquiry you submit to us regarding our Services or the services that we provide.
Information we collect from our partners and other sources
We may also obtain information about you from other sources and combine that with information we collect about you through your use of the Services. For example, we may obtain your contact information if you attend a conference or webinar that we sponsor and the organizer provides us with a list of attendees. We may also obtain your contact information from third parties that market mailing lists. If we receive Personal Information from a third-party source and/or if we combine the information we receive from these third-party sources with your Personal Information, we will treat that information as Personal Information. We are not responsible for the accuracy of the information provided by third parties or how such third parties collect, use and share such information.
Use of Personal Information
We use the Personal Information we collect to provide, maintain, protect and provide our Services, to develop new products and services, and to protect us and our customers. For example, we may use Personal Information about you for the following purposes:
- Facilitate and improve your online experience of the Services;
- To enable you to access and use the Services;
- To communicate with you, including contacting you electronically for the purposes of responding to your comments, questions and requests, providing customer services and support, providing you with information about any of our services, if any, providing you with technical notices, updates, security alerts and administrative messages. You can opt out of receiving such information at any time.
- To monitor and analyze trends, usage and activities on our Services;
- To investigate and prevent authorized access to our Services and other illegal activities;
- To protect and/or enforce our legal rights and interests, including defending any claims; and
- For other purposes authorized by you or applicable privacy laws.
Legal Basis for Use
Our legal basis for collecting and using Personal Information as a data controller will depend on the specific circumstances in which it was collected. In general, we process your Personal Information under the following legal basis:
- Consent – we process your Personal Information is you have consented to the processing activity. You may revoke your consent at any time, in which case we will cease further processing of your Personal Information based o your consent. This will however not impact the lawfulness of processing your Personal Information based on consent before it was withdrawn. Your access to and use of the Services might only be available based on consent.
- Contract – we process your Personal Information to perform our obligations to you under a contract.
Sharing of Personal Information
We must disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, we may share information about you as follows:
- To the maximum extent permitted by applicable law, in response to subpoenas or other legal process or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud;
- To protect the rights, property, life, health, security and safety of us or any third party;
- To the maximum extent permitted by applicable law, we may also use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you;
- With our affiliates for internal business purposes; and
- In connection with, or during negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, or any other type of acquisition of all or any portion of our assets, financing, disposal, conveyance or transfer of all or a portion of our business to another company, in this event you will be notified via prominent notice on our Services of any change in ownership or uses of your Personal information, as well as any choices you may have regarding your personal information; and
In our sole discretion, we may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
How long do we retain Personal Information?
We endeavour to only collect Personal Information that is reasonably necessary for the purposes for which they are collected, and to retain such data for no longer than is necessary for such purposes. The length of time Personal Information is retained, and criteria for determining that time, are dependent on the nature of the Personal Information, the purpose for which it was provided and any statutory retention periods. This is subject to any valid opt-out or withdrawal of consent where processing based on consent, or other valid exercise of your data subject rights.
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Although we use reasonable efforts to help protect your information, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through the Services.
We use third party services to host our Services, such as Amazon Web Services, Microsoft Corporation (the “Hosting Providers”) which store your Personal Information on secure and controlled environments administered by such Hosting Providers. Personal Information is encrypted when it is collected via the Services. For more information about the Hosting Providers’ privacy protection and data security practices, please visit https://aws.amazon.com/privacy/ and https://privacy.microsoft.com/en-ca/privacystatement.
We currently use third party analytical providers (e.g. HubSpot) which may collect analytic data on our behalf and in accordance with our instructions, and their applicable privacy policies.
We ensure that those who have permanent or regular access to Personal Information, or that are involved in the processing of Personal Information are trained and informed of their rights and responsibilities when process Personal Information. We take security seriously and will ensure that there are adequate policies and practices in place with respect to your Personal Information.
If you have any questions about security on our Services, you can contact is at firstname.lastname@example.org.
Links to third party sites
There may be features on the Services which enable you to subscribe to newsletters and other information about us. You can opt out of receiving communications from us at any time by following the instructions provided in those communications or emailing us at email@example.com with the subject of “Unsubscribe”. You may also remove yourself from our email list by clicking on the unsubscribe link presented in all communications we send to our users.
Depending on where you are located when you use or access the Services, your Personal Information may be transferred across international borders outside the country where you use or access the Services, including to countries outside the European Economic Area (“EAA”) that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases, we ensure that there is a legal basis for such transfer and that adequate protection for your Personal Information is provided as required by applicable law, for example, by using standard contractual clauses approved by the European Commission or other relevant authorities, by using certain service provides that are certified under the EU-US Privacy Shield, and by requiring the use of other appropriate technical and organizational information security measures. You may contact us at firstname.lastname@example.org to obtain additional information about the safeguards we take in connection with these transfers.
You have a right to know what Personal Information we hold about you, and to access it. This section describes the mechanisms for you to control certain uses and disclosures of your information.
Upon request, we will provide you with information about whether we hold any of your Personal Information. You have the right to access the Personal Information we have about you. You may correct, amend, or delete that information at any time by emailing email@example.com a Personal Information Request. We will respond to your access request within a reasonable time period. We may require additional information from you to allow us to confirm your identity. There may be circumstances in which we may not be able to accommodate your request to change information if we believe that the change would violate any law or legal requirement or cause the information to be incorrect. Please note deleting the Personal Information we hold about you may result in you not being able to access or use the Services. All requests for the removal of Personal Information shall be responded to within a reasonable period of time.
In the event you have provided Personal Information to subscribe for newsletters and other information about us, you are free to opt-out of receiving such information at any time. To opt out of receiving communications from us please email us at firstname.lastname@example.org with the subject of “Unsubscribe”. You may also remove yourself from our email list by clicking on the unsubscribe link presented in all communications we send to our users.
Your browser software can be set to reject all cookies, but if you reject our cookies, certain functions and conveniences of the Services may not work properly. To learn more about cookies, please check your browser’s help or similar feature or visit www.allaboutcookies.org. Some web browsers incorporate a “do-not-track” or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his or her online activity tracked. Please check your browser’s help or similar feature for more information about this process.
If you are an individual from the EEA, and access or use the Services from the EEA, we process your Personal Information both as a Processor and as Controller, as such terms are used in the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”). Our legal basis for collecting and using the Personal information will depend on the Personal Information concerned and the specific context in which we collect it. We process your Personal Information as a processor and controller when your access or use the Services and submit Personal Information to us. Our legal basis for acting as a controller and processor is further described above under the “Legal Basis for Use” section.
If you are an individual from the EEA, and access or use the Services from the EEA, you have certain additional rights provided by the GDPR as follows:
a. Right to be informed of how your Personal Information is used – you have a right to be informed about how we will use and share your Personal Information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and pain language.
b. Right to access Personal Information – you have a right to obtain confirmation of whether we are processing your Personal Information, access your Personal Information and information regarding how your Personal Information is being used by us.
c. Right to have inaccurate Personal Information rectified – you have a right to have any inaccurate or incomplete Personal Information rectified. If we have disclosed the relevant Personal Information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible.
d. Right to have the Personal Information erased in certain circumstances -you have a right to request that certain Personal Information held by us is erased. This is also known as a right to be forgotten. This is not a blanket right to require all Personal Information to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your Personal Information.
e. Right to restrict processing of Personal Information in certain circumstances – you have a right to block the processing of your Personal Information in certain circumstances. This right arises if you are disputing the accuracy of the Personal Information, if you have raised an objection to processing, if processing of the Personal Information is unlawful and you oppose erasure and request restriction instead or if the Personal Information is no longer required by us but you require the Personal Information to be retained to establish, exercise or defend a legal claim.
f. Right to data portability – in certain circumstances you can request to receive a copy of you Personal Information in a commonly used electronic format. This right only applies to Personal Information that you have provided to us (such as Identity Information, Contact Information). The right to data portability only applied if the processing is based on your consent or if the Personal Information must be processed for the performance of a contract and the processing is carried out by automated means.
g. Right not be to subject to automated decisions – you have the right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.
h. Right to object to processing of Personal Information – you have a right to object to the processing being carried out by us if we are processing Personal Information based on a legitimate interest or if we are using Person Information for direct marketing purposes or if the information is being processed for scientific or historical or other statistical purposes. You will be informed that you have the right to object at the point of data collection and the right will be brought explicitly to your attention.
You may exercise any of your rights referred to above by contacting the Data Protection Officer at email@example.com. We may require additional information from you to allow us to confirm your identity.
This California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act of 2023 (“CPRA”) disclosure explains how we collect, use, and disclose Personal Information relating to California residents covered by the CCPA and CPRA. Under the CCPA and CPRA, the specific Personal Information that we collect, use, and disclose relating to a California resident will vary based on our relationship or interaction with that individual.
Information We Collect
We have collected the following categories of Personal Information on consumers as defined under the CCPA and CPRA within the last twelve (12) months:
A real name, IP address, email address, or other similar identifiers.
B. Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code §1798.80(e))
A name, signature, Social Security Number, address, telephone number, passport number, driver’s license number, insurance policy number, education, employment history, bank account number, credit card number, financial information, medical information, or health insurance information.
C. Protected classification characteristics under California or Federal law.
Age, race, ancestry, national origin, citizenship, religion, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, pregnancy, childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.
D. Commercial information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric Information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or similar network activity
Browsing history, search history, information on interaction with a website, application, or advertisement.
G. Geolocation Data
Physical location or movements.
H. Sensory Data
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 CFR Part 99).
Education records directly related to a student maintained by an educational intuition or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Personal information does not include:
- Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s or CPRA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from information you provide on the Services, market research surveys or through a job application.
- Indirectly from you. For example, from observing your actions on the Services.
- We retain your data pursuant to our records retention policy.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name, contact information, and resume to be considered for a job posting, we will use that Personal Information in evaluating your qualifications for that position.
- To provide you with support and respond to your inquiries, including to investigate your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or government regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA and CPRA.
- We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosing Personal Information
We may disclose your Personal Information to a client, contractor or service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter a legal agreement that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories (corresponding with the table above) of Personal Information for a business purpose: Category A, Category B, Category C, Category D and Category I.
We disclose your Personal Information with the following categories of third parties: our clients, our service providers, and third parties to whom you or your agents authorize us to disclose your Personal Information in connection with Services.
In the preceding twelve (12) months, we have not sold any Personal Information.
Your Rights and Choices
The CCPA and CPRA provide California residents with specific rights regarding their Personal Information. This section describes your CCPA and CRPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal and sensitive information unless responding to the request is impossible or involves disproportionate effort. Once we receive and confirm your verifiable request, we will disclose to you:
- The categories of Personal Information and sensitive information we collected about you.
- The categories of sources for the personal and sensitive information we collected about you.
- Our business or commercial purpose for collecting, using and/or disclosing that information.
- The categories of third parties, contractors and service providers with whom we share, sell or disclose that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, a list of those disclosures, identifying the Personal Information categories that each category of recipient obtained.
- Whether your information is sold or shared.
- The retention period or criteria used for retention.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Help to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for those purposes..
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
How to Exercise Your CCPA/CPRA Rights
If you are a California resident, you may submit a request by contacting our Privacy Officer at: firstname.lastname@example.org
COLORADO, VIRGINIA, UTAH AND CONNECTICUT RESIDENTS
If you are a Colorado, Virginia, Connecticut or Utah resident and the processing of personal information about you is subject to these state laws, subject to certain limitations, you have the following rights:
- Right of Access: You have the right to confirm whether we process your personal information and request to access to such Personal Information.
- Right to Deletion: You have the right to request that we delete personal information we have collected about you.
- Right to Data Portability: You have the right to request that we provide you with your personal information in a portable format.
Colorado, Connecticut and Virginia only:
- Right to Correction: You have the right to correct inaccuracies in your personal information.
- The Right to Opt Out: You have the right to opt out of targeted advertising, the sale of your personal information and profiling in furtherance of decisions that produce legal or similarly significant effects.
You may have the right to appeal a denial of any of the above-listed rights. You may do so by by contacting our Privacy Officer at email@example.com.
CHILDREN UNDER 13
The Child Online Privacy and Protection Act (“COPPA”) regulates online collection of information from persons under the age of 13 (each, a “covered person”). We maintain procedures to assure that information about children or other categories of sensitive information is only collected with explicit consent and is protected against improper use, consistent with applicable laws.
Prior to conducting a research project, whether through the Services or otherwise, with children or young people, we will identify and comply with any applicable laws including COPPA, which requires verifiable parental or legal guardian’s consent for interviewing children below the age of 13 years. If you are a parent of a covered person, you may revoke your consent, review your covered person’s personal information, ask to have it deleted, and/or refuse to allow any further collection or use of your child’s information at any time by contacting our Privacy Officer at firstname.lastname@example.org.
THIRD PARTY DATA COLLECTION; NATIONAL LAWS