Effective Date: January 23, 2020
If you have any questions about this Policy, please contact us via e-mail at: firstname.lastname@example.org.
1. Changes to this Policy
We reserve the right to revise this Policy from time to time by updating it and posting it at https://www.sociallicenseplatform.com/privacy-policy/, with the new terms taking effect on the date of posting. You should periodically review this Policy to ensure you are familiar with the most current version. Your use of the Site after the Effective Date posted above constitutes your acceptance of the updated Policy.
2. Information Collection
A. General. When you visit the Site, you can browse without submitting any personal information about yourself. We will, however, receive and store some non-personally identifiable information about you, as described below. In order for you to connect or to be connected with Businesses or Service Providers, you will be required to register an account as a Business, Service Provider, or both through the Site and create a profile (the “Account”). In order to participate in certain functionalities, including creating, using, or accessing your Account, you may be asked to provide personally identifiable information (“Personally Identifiable Information”). Personally Identifiable Information is information that can identify you, including, for example, your name, username, postal address, telephone number, or e-mail address. It will always be your choice, or the choice of anyone acting for you, to provide Personally Identifiable Information.
B. Account and Login Information. We will collect Personally Identifiable Information from you when you create an Account. If you create an Account, you will be asked to provide information about yourself, including, but not limited to, your name, e-mail address, username, and password selected by you. It is your responsibility to keep your information up to date and to ensure that we have an active and deliverable e-mail address for you. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.
C. E-mail Address Collection; Newsletter. In order to receive certain communications from us, including, but not limited to, our newsletter, you may be required to submit your name and e-mail address to us. Any e-mail communication you receive from us will include our contact information and an unsubscribe link that will allow you to opt-out of receiving future e-mails.
D. Public Content. You may provide information through the Site that is intended for public consumption and is therefore viewable by the public, including photos, ratings, comments, reviews, tips, lists, project details, real-estate or land information, and business information.
E. Location Information. If you use the Site, we may receive your generic location (such as city or neighborhood) or, with your consent, precise geographic location data. We may use and store this information to provide and improve features of the Site, for example, to tailor the Site on a needs-based manner to better facilitate your use of the Site or to provide users, typically companies and investors (“Business” or “Businesses”) and experts, including but not limited to consulting firms, nonprofit organizations, civil society organizations, community based organizations, academics, and independent consultants (“Service Provider” or “Service Providers”) with information relating to land and responsible land-based investment and projects.
F. Automatically Collected Information. Similar to other websites, we may collect some information automatically and store it in log files, regardless of whether you create an Account. This information does not identify you. This collection may include, but is not limited to: your domain name and host for Internet access, the Internet address of the site from which you came, the date and time of your access, your computer’s IP address and information about its operating system, browser, and host, the date and time you access the Site, and the pages you visit. We collect this non-personally identifying information in order to help diagnose problems with our server and to administer the Site. We may automatically collect information using various tracking technologies, such as cookies.
H. “Do-Not Track” Settings. Because we track website usage information as described above, your selection of the “Do Not Track” option provided by your browser or device may not have any effect on our collection of certain information. The only way to completely “opt out” of the collection of information through cookies or other tracking technologies is to actively manage the settings on your browser or device to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website may not be able to control other websites.
3. Information Use
A. Use of Personally Identifiable Information. We may use your Personally Identifiable Information that you provide us, such as your e-mail address, to send you occasional updates and our newsletter. You may also receive e-mails or other communications from us in response to inquiries that you submit to contact us or request more information regarding our Site and Content. When you receive a promotional or informational e-mail communication from us, the e-mail will contain our contact information and an unsubscribe link that will allow you to opt-out of future e-mails from us. If you opt-out, you will still continue to receive e-mail responses to your inquiries or other service-related e-mails related to your use of the Site. We may also use Personally Identifiable Information to resolve disputes; to detect and protect against errors, fraud, and criminal activity; to assist law enforcement; to enforce this Policy and the Terms; or for any other purpose described in this Policy or that we describe to you at the time of collection.
B. Use of Non-Personally Identifiable and Aggregate Information. We may use non-personally identifiable information for any lawful purpose including, but not limited to, analyzing trends, administering the Site, tracking users’ movements on the Site, and managing and improving the Site. We may also use this information to store information about your device so that you will not have to re-enter it the next time you visit the Site; to monitor aggregate metrics such as total number of visitors or pages viewed; or to track submissions in any interactive portion of the Site. We may also combine non-personally identifiable information with non-personally identifiable information collected from other sources.
C. Information Retention. We will retain your information indefinitely, or as long as legally required or allowed. We may dispose of any information in our discretion without notice, subject to applicable law. We do not undertake any retention obligations through this statement.
4. Information Disclosure
A. Affiliated Entities or Service Providers. We will not sell or rent any of your Personally Identifiable Information to third-parties for marketing purposes. We may use third-parties to help us operate the Site. For instance, we may use third-parties to process payments or to provide advertising and analytics information for our Site. See “Orders and Payment Processing” and “Third-Party Analytics” above for more information.
B. Business Partners. When we work with Businesses and Service Providers, we may share information, including Personally Identifiable Information, with those Businesses and Service Providers only as needed to provide services, including matching Businesses and Service Providers, and subject to this Policy or an agreement at least as restrictive as this Policy.
C. Legal Requirements. In some cases, we may disclose your information, including Personally Identifiable Information: (i) as required by any applicable law, rule or regulation; (ii) if we believe disclosure is needed to protect our rights, property or safety; (iii) to government regulators or law enforcement authorities in connection with any judicial proceeding, court order, subpoena or legal process served on us or the Site; and (iv) to respond to a physical threat to you or another person.
D. Insolvency and Business Transitions. If we should ever file for bankruptcy or engage in a business transition such as an acquisition by or merger with another company, or if we sell or reorganize all or part of our business or assets, we may disclose your information, including, but not limited to, Personally Identifiable Information, to prospective or actual purchasers or transaction participants in connection with these transactions.
E. Disclaimer. We cannot ensure that all of your Personally Identifiable Information will never be disclosed in ways not otherwise described in this Policy. For example, a third-party may unlawfully intercept or access transmissions or private communications, or other users of the Site may abuse or misuse your Personally Identifiable Information. No transmission of data over the Internet can be 100% secure.
5. Information Security Measures
We exercise care in facilitating the transmission of information between your device or computer and the third-party servers that operate and store information for the Site. The Personally Identifiable Information we collect is stored in operating environments that are not available to the public. While we have mechanisms in place to safeguard your Personally Identifiable Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
6. Children’s Privacy.
A. This Site is not for or Directed Towards Children. Our primary audience is adults. The Site is not intended for anyone under the age of 18 or under the age of legal majority in your place of residence. We do not intend to and will not knowingly collect any Personally Identifiable Information from children under the age of 13. Children under the age of 13 are prohibited from using the Site. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers. If you believe information from a child under the age of 13 has been provided to the Site, please notify us via e-mail at: email@example.com.
B. California Minors. While the Site is not intended for anyone under the age of 18, if you are a California resident under age 18 and you believe your information has become publicly-available through the Site and you are unable to remove it, you may request removal by contacting us via e-mail at: firstname.lastname@example.org. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any content or information that: (i) federal or state law requires us or a third-party to maintain; (ii) was not posted by you; (iii) is anonymized so that you cannot be identified; (iv) you do not follow our instructions for removing or requesting removal; or (v) you received compensation or other consideration for providing the Content or information.
REMOVAL OF YOUR CONTENT OR INFORMATION FROM THE SITE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
7. Your California Privacy Rights; California Shine the Light Law
California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request, you may do so by contacting us via e-mail at: email@example.com.
8. Linked Sites.
9. Accessing, Updating, or Deleting your Personal Information
If Personally Identifiable Information that you have submitted to us changes or if you would like to remove your Personally Identifiable Information, please contact us via e-mail at: firstname.lastname@example.org. We will make good faith efforts to resolve requests to remove information or correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.
10. Privacy Shield
We comply with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Frameworks administered by the US Department of Commerce (together, “Privacy Shield”) regarding the processing of Personally Identifiable Information from European Union member countries and Switzerland. This means that we adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov.
11. The General Data Protection Regulation (“GDPR”)
Residents of the European Economic Area (“EEA”) may be entitled to rights under the GDPR. These rights are summarized below. We may require you to verify your identity before we respond to your requests to exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to your Personally Identifiable Information that we collect and store:
- the right to withdraw your consent to data processing at any time (please note that this might prevent you from using certain aspects the Site);
- the right of access your Personally Identifiable Information;
- the right to request a copy of your Personally Identifiable Information;
- the right to correct any inaccuracies in your Personally Identifiable Information;
- the right to erase your Personally Identifiable Information;
- the right to data portability, meaning to request a transfer of your Personally Identifiable Information from us to any other person or entity as chosen by you;
- the right to request restriction of the processing of your Personally Identifiable Information; and
- the right to object to processing of your Personally Identifiable Information.
You may exercise these rights free of charge. These rights will be exercisable subject to limitations as provided for by the GDPR. Any requests to exercise the above-listed rights may be made to: email@example.com. If you are an EEA resident, you have the right to lodge a complaint with a Data Protection Authority about how we process your Personally Identifiable Information at the following website: https://edpb.europa.eu/about-edpb/board/members_en.
12. International Data Transfer and Personally Identifiable Information
If you provide Personally Identifiable Information to us, we may transfer, process, use, or store this information in any country where we have operations, including countries outside of the United States and the EEA. We may transfer your Personally Identifiable Information to a country other than the country where it was collected for processing consistent with this Policy. Do not provide Personally Identifiable Information to us if you do not consent to this information being transferred outside of the United States or the EEA. Your Personally Identifiable Information may be transferred to a country where privacy laws may not be as protective as in your place of residence. If we transfer your Personally Identifiable Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- European Commission Standard Contractual Clauses: We may use specific contracts approved by the European Commission which give Personally Identifiable Information the same protection it has in the EEA.
- Privacy Shield: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personally Identifiable Information shared between the Europe and the US.
For additional information on the mechanisms used to protect your Personally Identifiable Information, please contact us via e-mail at firstname.lastname@example.org.
If for any reason you believe that we not adhered to these privacy principles, please notify us by e-mail at email@example.com, and we will endeavor to review and correct the problem promptly. This Policy shall be enforced in accordance with the Governing Law provision in the Terms, which can be viewed at: https://www.sociallicenseplatform.com/welcome-2-2/about/terms-of-use/.
14. Third Party Beneficiaries
The Munden Project Limited (“TMP”) is implementing the Site with us and is entitled to enforce certain or all of the provisions of this Policy, as may be agreed by us and TMP.
15. Contact Information and Privacy Questions
If you have a question about this Policy or other matters that relate to it, you may contact us by going to the “Contact” link on our home page and using the form located there, or by contacting us via e-mail at: firstname.lastname@example.org.