Last updated: August 25th, 2020
Thank you for using Paladin’s free tools for legal services organizations! As a quick reminder, Paladin does not provide legal services, but rather is a technology tool that helps organizations streamline their pro bono referrals to partner organizations.
When you use Paladin’s tools to refer pro bono opportunities or manage your pro bono program, you are agreeing to our terms, so please take a few minutes to review this Legal Service Organization User Agreement (“LSO User Agreement”). The LSO User Agreement includes the following, as well as Paladin’s Acceptable Use Policy, Service Level Agreement, and Privacy Policy, which are standard across all Paladin’s pro bono software and services (“Paladin’s Services”).
In addition, by using Paladin’s free tools, you agree to Paladin displaying your organization’s name and contact information to other Paladin partner organizations for the purpose allowing them to select you as a pro bono partner. Contact information may include the first and last name, email address and phone number of the designated user(s) at your organization. By inputting this data, you represent that you have the appropriate authority and consent to do so. This information will not be viewable publicly on the internet, but will be viewable to all law firms, corporate legal teams and portal clients using Paladin on their private password protected interfaces, as well as any public platforms you may post opportunities to, or individuals who may view your opportunities via your use of the “create link” functionality outlined below. Paladin may also disclose the name of organizations using Paladin to potential law firms, corporate legal teams and portal clients.
By posting opportunities, you understand and agree that any opportunities you share will be 1) viewable by any and all users at the designated partner organization and offices (i.e. New York office of law firm X) that you select to share the opportunity with, and 2) in the case of a statewide or public portal, viewable by the general public and findable via search engines, and 3) in the case of semi-public links that you generate using Paladin’s “create link” functionality, viewable to recipients that you share the link with, and whomever they may send it to, and so on. Paladin is not responsible or liable for the sharing of opportunities in this way.
By posting opportunities on Paladin, you agree not to include personally identifiable information (“PII”) regarding pro bono clients or other individuals. In turn, Paladin does not own opportunity data, and your opportunities are not editable by other Paladin users outside of your organization. Paladin agrees not to use or share opportunity data, except it may use such data 1) internally to improve and enhance the Services and for other development, diagnostic and corrective purposes in connection with the Services or 2) in an anonymized and aggregated format.
Paladin’s Acceptable Use Policy
This Acceptable Use Policy (“AUP”) describes actions that Paladin prohibits when any party uses Paladin’s Services. A user may not affirmatively or deliberately use the Services in a manner that involves, facilitates, or attempts any of the following:
- Violating any law of, or committing conduct that is tortuous, fraudulent, abusive or unlawful in, any applicable jurisdiction;
- Accessing, sending, receiving, displaying, performing, disclosing, storing, or executing any content a) in violation of any copyright, right of publicity, patent, trademark, service mark, trade name, trade secret or other intellectual property right, b) in violation of any applicable agreement, or c) without authorization;
- Attempting to bypass or break any security mechanism on Paladin or using Paladin in any other manner that poses a material security or service risk to Paladin or any of its other customers;
- Deleting or altering author attributions, copyright notices, or trademark notices, unless expressly permitted in writing by the owner;
- Obtaining unauthorized access to any system, network, service, or account;
- Interfering with service to any user, site, account, system, or network by use of any program, script, command, or otherwise;
- Introducing or activating any viruses, worms, harmful code and/or Trojan horses
- Transmitting any material that is, facilitates, or encourages libelous, defamatory, discriminatory, or otherwise malicious or harmful speech or acts to any person or entity, including but not limited to hate speech, and any other material that Paladin reasonably believes degrades, intimidates, incites violence against, or encourages prejudicial action against anyone based on age, gender, race, ethnicity, national origin, religion, sexual orientation, disability, geographic location or other protected category
- Displaying, performing, sending, receiving or storing any content that is obscene, pornographic, lewd, lascivious, or excessively violent, regardless of whether the material or its dissemination is unlawful;
- Advocating or encouraging violence against any government, organization, group, individual or property, or providing instruction, information, or assistance in causing or carrying out such violence, regardless of whether such activity is unlawful;
- Reselling Paladin’s services, in whole or in part, to any entity or individual, without Paladin’s prior written consent, or misrepresenting your relationship with Paladin.
Questions about this Policy (e.g., whether any contemplated use is permitted) and reports of violations of this Policy should be directed to [email protected].
Paladin’s Service Level Agreement
The Services shall be available 99.9% of the time, seven (7) days a week, twenty-four (24) hours per day, measured monthly, excluding scheduled maintenance of which Paladin has informed Customer in advance, and which is scheduled within the Standard Maintenance Window (“Service Availability”). “Standard Maintenance Window” means the hours of 9:00 pm to 6:00am ET Monday through Friday, or 9:00 pm ET Friday through 6:00am ET Monday. If Customer requests maintenance outside of the Standard Maintenance Window, any uptime or downtime calculation will also exclude periods of downtime due to such maintenance; provided that Paladin has notified customer that such maintenance may result in downtime. Further, any downtime resulting from outages of Paladin’s third party hosting providers or of utilities, which are beyond Paladin’s control, will also be excluded from any such calculation. Paladin’s blocking of data communications that violate its Acceptable Use Policy shall not be deemed to be a failure of Paladin to provide adequate service levels under this Agreement.
Paladin’s Privacy Policy
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
– You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
– Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
– Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Paladin PBC, Inc., 386 Park Avenue S, Fl 5, New York, NY 10016. For the purpose of the GDPR, the Company is the Data Processor.
– Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
– Account means a unique account created for You to access our Service or parts of our Service.
– Website refers to Paladin, accessible from https://www.joinpaladin.com/
– Service refers to the Website.
– Country refers to: New York, United States
– Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
– Personal Data is any information that relates to an identified or identifiable individual.
– For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
– For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
– Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
– Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
– Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
– Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
– Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
– Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
– Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide, or your employer may provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- City
- Office
- Title(s)
- Department or practice area
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service, or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
- For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
Hosting
We use third-party Service providers to host our Service.
Amazon Web Services
AWS is a web hosting service offered by Amazon that hosts our application. Batch user upload information (including, but not limited to, full names, email addresses, phone number and bar license) stored privately in its S3 storage service and encrypted at rest.
For more information on the privacy practices of AWS, please visit the Amazon Privacy Terms web page: https://policies.google.com/privacy?hl=en
Heroku
Heroku is a hosting provider. Most user data is stored here with the exception of data stored in S3. For more information on the privacy practices of Heroku, please visit the Salesforce Privacy Terms web page: https://policies.google.com/privacy?hl=en
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
Mixpanel
Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
Intercom
Intercom is a customer success and basic analytics platform. Data shared may include email addresses, full names, company/organization names, city/state and user correspondence via Intercom. For more information on the privacy practices of Intercom, please visit the Intercom Privacy Terms web page: https://www.intercom.com/terms-and-policies#privacy
Segment
Segment is an analytics aggregation platform. Data shared may include email addresses and full names. For more information on the privacy practices of Segment, please visit the Segment Privacy Terms web page: https://segment.com/docs/legal/privacy/
Monitoring
Sentry
Sentry is a monitoring platform that logs exceptions in the application and, in doing so, may share user data. For more information on the privacy practices of Sentry, please visit the Sentry Privacy Terms web page: https://sentry.io/privacy/
LogDNA
LogDNA is an application logging provider (via Heroku) which logs exceptions, through which user data may be shared. For more information on the privacy practices of LogDNA, please visit the LogDNA Privacy Terms web page: https://logdna.com/privacy/
New Relic
New Relic is a monitoring platform that logs exceptions, through which user data may be shared through Heroku. For more information on the privacy practices of New Relic, please visit the New Relic Privacy Terms web page: https://newrelic.com/termsandconditions/privacy
Email Marketing
We may use Your Personal Data to contact You with pro bono digests, newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
Sendgrid
We may use Email Marketing Service Providers such as Sendgrid to manage and send emails to You. Sendgrid is owned by Twilio, and you can read more about the privacy practices of Twilio at their web page: https://www.twilio.com/legal/privacy.
Mailchimp
We use Mailchimp to send out newsletters and other such communications, which may involve sharing user name and email addresses. For more information on the privacy practices of New Relic, please visit the New Relic Privacy Terms web page: https://mailchimp.com/legal/privacy/
Other
Okta
Okta is a SSO management service sometimes used by Paladin clients. Email addresses are shared if clients use SSO through Okta. For more information on the privacy practices of Okta, please visit the Okta Privacy Terms web page: https://www.okta.com/privacy-policy/
Typeform
Typeform is a webform-as-a-service platform. Typically, PII is not shared, possible exceptions include first names, last names, and email when Users fill out reporting forms. For more information on the privacy practices of Typeform, please visit the Typeform Privacy Terms web page: https://admin.typeform.com/to/dwk6gt
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You, your employer and/or for any pre-contractual obligations thereof.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by your employer, who is a client of the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
CCPA Privacy
Your Rights under the CCPA
Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:
- The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
- The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.
Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- From Our “Cookie Consent” notice banner
- Or from Our “CCPA Opt-out” notice banner
- Or from Our “Do Not Sell My Personal Information” notice banner
- Or from Our “Do Not Sell My Personal Information” link
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Mobile Devices
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Privacy Shield
We have subscribed to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”). We adhere to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”), the United Kingdom (“UK”) and Switzerland.
If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles as concerns the Personal Data received under the Privacy Shield, the Privacy Shield Principles shall govern to the extent of the conflict. To learn more about the Privacy Shield program visit www.privacyshield.gov, and to view our certification, please visit https://www.privacyshield.gov/list.
Privacy Shield Principles
1. and 2. Notice and Choice
Our Privacy Policy describes how we use Personal Data we receive from different sources. This Privacy Shield Policy describes how we process Personal Data covered by the Privacy Shield.
If you are a User, We may act as a data processor for you in relation to the Personal Data that your employer provides or makes available to Us. We usually will not have a relationship with Users. Here, the employer, as the data controller, is responsible for ensuring that Users are provided with appropriate notice and choice with respect to their Personal Data.
In its role as a controller and as required by applicable law, We generally offer individuals in the EU, UK and Switzerland (together: “EEA/UK/CH Individuals”) the opportunity to choose whether their Personal Data may be (i) disclosed to third-party controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant EEA/UK/CH Individuals. To the extent required by the Privacy Shield Principles, We obtain opt-in consent for certain uses and disclosures of sensitive data. EEA/UK/CH Individuals may contact Us as indicated below regarding Our use or disclosure of their Personal Data. Unless We offer EEA/UK/CH Individuals an appropriate choice, We use Personal Data only for purposes that are materially the same as those indicated in this Policy.
3. Data Integrity and Purpose Limitation
We only collect Personal Data that is relevant to providing our Services. We process Personal Data compatible with us providing the Services or as otherwise notified to you. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed for Our Services, accurate, complete, and current.
4. Accountability for Onward Transfers
This Privacy Policy describes how We share Personal Data. Except as permitted or required by applicable law and in accordance with Our role as a controller or processor, We provide EEA/UK/CH Individuals and Users with an opportunity to opt out of sharing their Personal Data with third-party processors. We require third-party processors to whom it discloses the Personal Data of EEA/UK/CH Individuals and Users to contractually agree to (a) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant EEA/UK/CH Individuals and Users, (b) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (c) notify Us and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party processor determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.
We may disclose Personal Data to trusted third parties as indicated in the Privacy Policy without offering an opportunity to opt out. We require that its agents and service providers that have access to Personal Data within the scope of this Privacy Shield Policy provide the same level of protection as required by the Privacy Shield Principles. We ensure that our agents process Personal Data received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
We may also need to disclose Personal Data in response to lawful requests by public authorities, for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law. We do not offer an opportunity to opt out from this category of disclosure.
5. Data Security
We use reasonable and appropriate physical, electronic, and administrative safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data and the risks involved in processing that information
6. Access to Personal Data
Our Privacy Policy explains how you may access and/or submit requests to review, correct, update, suppress, or delete Personal Data. You can ask to review and correct Personal Data that we maintain about you by sending a written request to [email protected]. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles.
7. Recourse, Enforcement and Dispute Resolution
If you have any questions or concerns, please write to us at [email protected]. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Shield Principles.
In the event we are unable to resolve your concern, you may contact JAMS, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
Children’s Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, or to exercise your rights under the Policy, You can contact us by email at [email protected].