We Are The Doe

The Doe is a media and tech company creating paths to improved civil discourse.

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Last updated 09/07/2021

Effective as of July 15, 2021.

This “Privacy Policy” describes the privacy practices of The Doe, Inc. and our subsidiaries and affiliates (collectively, “The Doe”, “we”, “us”, or “our”) in connection with the www.thedoe.com website (the “Site”), and any other website that we own or control. We invite you to read this Privacy, which explains our privacy practices and how we treat your personal information when you use or access the Site. It describes the types of personal information collected and created in connection with your use or access to the Site, how and why we use such information, who we share it with, and your legal rights. Certain portions of this Policy apply only to Sites offered in particular geographies

Personal Information We Collect

We collect a variety of information from you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third party source.  

Information you provide to us:

  • When you sign up for a free account, you may provide your email address and name. 
  • When you sign up for a Member account, you provide your email address, name, and credit card details.
  • When you interact with our customer support, you provide your email address, name, as well as any other information you decide to share with us. 
  • When you sign up to receive our newsletter, you provide your email address and name.
  • When you participate in an event or a contest, you provide your account details as well as any other information you decide to share with us.
  • When you decide to take part in our Personal Assessment Quiz to get your Doe Print, you provide us with your email address or account details. You may also decide to provide us with sensitive information, such as information about your political beliefs, mental health, sexual orientation, ethnic or racial origin, religious or philosophical beliefs. Sensitive information will only be collected with your consent and will only be used in accordance with this privacy policy. 

Information we obtain from social media platforms:

  • When you visit or interact with our pages on social media platforms, such as Facebook, LinkedIn, Twitter, Instagram, and other third party platforms, you are agreeing to the platform provider’s privacy policy. This may include sharing with us your name, profile, photos, reactions and comments to our posts, etc. The platform provider’s privacy policy  applies to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
  • Data from other accounts.  If you use a third party, like Google, to log in to the Site (or later connect your third party account to your The Doe account), then you authorize the third party to share your personal information with us, including your name, username, photo, email address, and any other information you agree to share. The platform provider’s privacy policy applies to your interactions and their collection, use and processing of your personal information.
  • When you chat with us on Keybase, although this platform is meant to protect your anonymity, you may decide to share with us some personal information about yourself.

Information we obtain from other third parties. 

We may receive personal information about you from third-party sources. For example, we may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Information collected by automated means from your browser and device through cookies and other tracking technologies

With your permission where it is required by applicable laws, We, our  providers, and our business partners may automatically log information about you, your browser, your computer or mobile device, and your activity on the Site. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Site, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons.

See our Cookie Policy for more information.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To provide our products and services, and operate the Site. We use your personal information to:

  • provide, operate and improve the Site, and our products and services
  • establish and maintain your user profile on the Site
  • provide you with the results of the personal assessment quiz and give you access to your Doe print 
  • provide you with personalized content based your Doe print
  • enable security features of the Site, such as by sending you email when you forget your account password, and remembering devices from which you have previously logged in
  • communicate with you about the Site,our products and services, including by sending you announcements, updates, security alerts, and support and administrative messages
  • communicate with you about events or contests in which you participate or charity for which you voted
  • understand your needs and interests, and personalize your experience with the Site and our communications
  • provide support and maintenance for the Site
  • respond to your requests, questions and feedback.

To administer events and contests.

We use your personal information to register your participation in the events and contests that we organize, and to send you updates about such events and contests.

For research and development. 

We analyze use of the Site to analyze and improve the Site and to develop new products and services, including by studying user demographics and use of the Site.

To send you marketing and promotional communications. 

With your consent where required by applicable laws, We may send you The Doe-related marketing communications. You will have the ability to opt-out of our marketing and promotional communications at any time as described in the opt-out of marketing section below.

To display advertisements. 

We work with advertising partners to display advertisements elsewhere online. These advertisements may be targeted based on your use of the Site or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”

For compliance, fraud prevention, and safety. 

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the Terms of Use that govern the Site; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To create anonymous, aggregated or de-identified data. 

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.

To comply with law. 

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

With your consent. 

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How We Share Your Personal Information

We share your personal information with third parties where it is necessary to provide our products and Sites, and for purposes described in this Privacy Policy:

Affiliates. 

We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. 

We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Site (such as customer support, hosting, analytics, email delivery, marketing, quality assurance vendors, IT services and developers,  and database management services). Our service providers include notably Shopify, Auth0, Stripe, FaunaDB, Hubspot, ZenDesk, Product Board, and Google. These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Partners. 

We may sometimes share your personal information with partners or enable partners to collect information directly via our Site. Our partners include notably Google, Facebook, Instagram, LinkedIn,Twitter, YouTube, Pinterest, Medium, Quora, New Relic, Hubspot, Hotjar, and Spotify. Please read our partners’ privacy policy to understand how they use your personal information.

Third-party platforms and social media networks. 

If you have enabled features or functionality that connect the Site to a third-party platform or social media, we may disclose the personal information that you authorized us to share. In particular, our Site includes certain social media features, including social media share buttons. If you choose to share a post using the social media share button, information about that Content will be shared with Facebook, Twitter, Messenger, etc. We do not control the third party’s use of your personal information. Please consult the third-party platforms’ privacy policy to understand how they use your personal information.

Professional advisors. 

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others for compliance, fraud prevention and safety. 

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transferees. 

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. 

If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt-out of marketing communications.

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected] You may continue to receive service-related and other non-marketing emails.

Targeted online advertising. 

Some of our business partners that collect information about your activities on or through the Site may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

You may opt out of receiving targeted advertising on websites from members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you.  

Do Not Track. 

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. 

Please note that we may not be able to provide you with certain services if you choose not to share with us your personal information.

Third-party platforms or social media networks. 

If you choose to connect to the Site via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or Site. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

Other Sites, Mobile Applications and Services

The Site may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

European Union users should read the important information provided below about transfer of personal information outside of the European Union.

Children

The Site is not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us at [email protected]

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. We may, and if required by law, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Site.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting).

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to [email protected] You may also write to us via postal mail at:

The Doe, Inc.

Attn: Legal – Privacy

5318 E. 2nd Street, PMB 42540, Long Beach, California 90803

California Privacy Notice

This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information.  For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.  In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information in during the past 12 months:
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  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion. You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales. You can opt-out of any sale of your Personal Information.
  • Opt-in. If we know that you are under the age of 16, we will ask for your affirmative authorization to sell your Personal Information before we do so. 
  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. 

Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion at our webform or via email to [email protected]

Notice of right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you.  Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the advertising partners that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out of this “sale” of your personal information here: Do Not Sell My Personal Information.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency.  To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information.  Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465.  If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request. 

Personal Information that we collect, use and disclose. The list below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) , and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the list below, we disclose Personal Information as described in the How we share your Personal Information section above.  

Identifiers: 

  • Categories: Device identifiers, Internet protocol addresses, Advertising identifiers, Social media account identifiers, Username, Name or nickname, Information in your communications with us 
  • Sources: Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Purposes:Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Partners; Third-party platforms and social media networks; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: Advertising partners (to facilitate online advertising)

California Customer Records (as defined in California Civil Code §1798.80):

  • Categories: Device identifiers, Internet protocol addresses, Advertising identifiers, Social media account identifiers, Username, Name or nickname, Information in your communications with us, Credit card information, Information about your interaction with websites (e.g. referring/exit pages, number of clicks, pages viewed), Information about your interaction with advertisements, Membership information and information about your transactions with us, Information you choose to provide during your personal assessment or that you otherwise choose to upload to the service
  • Sources: You, Third-party sources, Automatic collection
  • Purposes:Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Partners; Third-party platforms and social media networks; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: Advertising partners (to facilitate online advertising)

Financial Information:

  • Categories: Credit card information
  • Sources: You
  • Purposes: Provide our products and services and operate the site; Compliance, fraud prevention and safety; Comply with law
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Professional advisors; Authorities and others for for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: None

Internet or Network Information:

  • Categories: Information about your interaction with websites (e.g. referring/exit pages, number of clicks, pages viewed), Information about your interaction with advertisements, Internet protocol address, Advertising identifiers, Device identifiers 
  • Sources: Automatic collection 
  • Purposes:Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Partners; Third-party platforms and social media networks; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: Advertising partners (to facilitate online advertising)

Commercial Information:

  • Categories: Membership information and information about your transactions with us
  • Sources: You, Third-party sources 
  • Purposes:Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: None

Inferences:

  • May be derived from: General geographic data, Information about your interaction with websites (e.g. referring/exit pages, number of clicks, pages viewed), Information about your interaction with advertisements, Information in your communications with us, Information from your activities on the site, including votes for charity
  • Purposes: Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: None

Protected Classification Characteristics:

  • Categories: Information you choose to provide during your personal assessment or that you otherwise choose to upload to the service, including gender, sexual orientation, race or national origin, or religious beliefs; Some protected classification characteristics may be inferable based on your interaction with the site, including from your votes for charities
  • Sources: You
  • Purposes: Provide our products and services and operate the site
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: None

Sensory Information:

  • Categories: Images, including profile pictures and other images you upload to the site or provide in communications to us and audio users choose to upload
  • Sources: You, Third-party sources (including social networks)
  • Purposes:Provide our products and services and operate the site; Administer events and contests; Research and development; Send marketing and promotional communications; Display advertisements; Compliance, fraud prevention and safety; Comply with law 
  • Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Partners; Third-party platforms and social media networks; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees
  • Categories of third parties to whom we “sell” PI: None

Shine the Light. Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at [email protected] or physical mail at 5318 E. 2nd Street, PMB 42540, Long Beach, California 90803. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Notice to Users Located in the EU and the UK

The information provided in this “Notice to Users located in the EU and the UK” section applies only to individuals located in the European Union or in the United Kingdom.

Personal information. 

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by EU and UK data protection legislations.

Controller. 

The Doe, Inc. is the controller of your personal information covered by this Privacy Policy for purposes of EU and UK data protection legislations.

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, The Doe, Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), The Doe, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

-by using EDPO’s online request form: https://edpo.com/gdpr-data-request/ 

-by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Legal bases for processing. 

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.

  • Performance of a contract

We process your personal information as is necessary to provide the services that you requested from us. For example:

  • we use your information in order to create your account and set you up as a member on The Doe.
  • We share your information with services provider to provide you with the services you requested.
  • Your Consent

We process certain information based on your consent, which you may revoke at any time. For example:  

  • we and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent;
  • we and our partners rely on your consent to provide you with tailored ads based on your actions and information, including based your activity on the Site and other websites;
  • we will send you marketing communications where you have consented to receiving such communications in accordance with applicable law;

When you take part in our personal assessment quiz, we may process sensitive personal information about you, such as information about your political beliefs, mental health, sexual orientation, ethnic or racial origin, religious or philosophical beliefs. We will only process such sensitive personal information when you have explicitly consented to it and will only use it to provide you with your Doe print and personalized content.

  • Legitimate Interests

We may process your information where it is necessary for the purposes of our legitimate interests or our partners’ legitimate interests. In particular, we process your information in furtherance of the following legitimate interests:

  • Keeping the Services safe and secure: We and our service providers use your information because it is necessary to pursue our legitimate interests in ensuring our Site is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Terms of Use.
  • Providing, improving, and developing the Services: We and our services providers use your information to provide the Site as well our products and services, including any personalized services, and to understand and improve our business. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our users and members on a sustained basis.
  • Providing ads, and measurement and analytics services: We and our partners use your information to provide personalized ads, and to measure and analyze the success of those ads in order to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests and our partners’ legitimate interests of marketing and monetizing our services.
  • Legal Obligation

We may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:

  • we may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and
  • we may retain and process your information where it is necessary for compliance with applicable laws.

As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

Use for new purposes. 

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention.

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights.

EU and UK data protection legislations give you certain rights regarding your personal information. If you are located within the European Union or the United Kingdom, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

Withdraw consent. Where we are relying on your consent for the processing of your personal information, you have the right to withdraw your consent at any time.

You may submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator:

Cross-Border Data Transfer

If we transfer your personal information outside of respectively the European Union or the United Kingdom to a country not deemed by the European Commission or the UK Government (as and where applicable) to provide an adequate level of personal information protection, we will either: 

  • enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or 
  • rely on other appropriate means permitted by GDPR Ch. V, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.