1. Managing Your Information Preferences
2. Information We Collect
We collect information that personally identifies you, such as your name, address, e-mail, phone number, and other personally identifiable information that you choose to provide us with (“Personal Information”).
Usage Data and Site Activity
We automatically collect information regarding the actions you take on the Site (“Usage Data”). For example, each time you use the Site we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. We use this information to help us understand how people use the Site and Services, and to enhance the services we offer.
Cookies and Anonymous Identifiers
What Cookies We Use?
We do not place cookies until you elect to continue using the Services after our cookie banner displays. We use performance cookies, which allow us to count visits and traffic sources, so we can measure and improve the performance of the Services. They help us know which pages are the most and least popular and see how visitors move around the Site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited the Services.
You can also learn more about cookies and set cookies preferences from allaboutcookies.org, www.aboutads.info/choices, and www.networkadvertising.org.
How we Deploy Cookies
Our Legal Basis for Processing Information Collected by Cookies
By continuing to browse on the Services you consent to us deploying cookies as described in this Policy. If you do not wish to accept cookies from the Services, or would like to stop cookies being stored on your device in the future, see opt out information in the chart below.
|PARTY SETTING COOKIE (E.G., THE OMIDYAR GROUP OR PARTNER)||TYPE OF COOKIE||PURPOSE/ FUNCTIONALITY||MORE INFORMATION AND HOW TO ADJUST SPECIFIC COOKIES’ SETTINGS|
|Google Analytics||Google Analytics is a site analytics tool that provides insight on user behavior. These cookies are used to better understand how users are using the Site so we can improve and optimize the Site, creating the best possible experience for users.||You can find out how to opt out of these cookies here.
This link will open in a new window. The Omidyar Group is not responsible for the content of external websites.
3. Service Providers
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved.
4. Online Tracking
5. Other Transfers
We may share Usage Data with businesses controlling, controlled by, or under common control with our Company. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Usage Data in connection with such transaction.
6. Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Usage Data to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
9. Children’s Privacy
The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publically posted on the Site or Services by e-mailing us at firstname.lastname@example.org. Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.
10. Processing in the United States
Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location.
The data controller for the Site and Services is:
The Omidyar Group
4348 Waialae Ave #368
Honolulu, HI 96816
Under EU data protection legislation, “Personal Information” includes a broad amount of information, including any information that can be used to identify, directly or indirectly, in particular by reference to an identifier such as an IP address, location data, and an online identifier. Since we may collect some if this type of information when we collect Usage Data, you may have additional protections under EU data protection legislation, if you reside in the EU. Under EU data protection legislation, we are only permitted to use your Personal Information if we have a legal basis for doing so. In addition to your consent, we rely on the following legal bases to use your information:
- Where we need to comply with a legal obligation
- Where the processing is necessary for us to carry out activities for which it is in The Omidyar Group’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our company and measure the reach and effectiveness of our company—this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively—this will include: processing for website content improvement; and processing for a statistical analysis of users’ behavior.
In more limited circumstances we may also rely on the following legal bases:
- Where we need to protect your interests (or someone else’s interests)
- Where it is needed in the public interest or for official purposes
You have a number of rights under EU data protection legislation in relation to your Personal Information, these include the right to:
- Be informed about how we use your Personal Information
- Obtain access to your Personal Information that we hold
- Request that your Personal Information is corrected if you believe it is incorrect, incomplete or inaccurate
- Request that we erase your Personal Information in the following circumstances:
- If we are continuing to process Personal Information beyond the period when it is necessary to do so for the purpose for which it was originally collected
- If we are relying on consent as the legal basis for processing and you withdraw consent
- If we are relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
- If the Personal Information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
- If it is necessary to delete the Personal Information to comply with a legal obligation
- Ask us to restrict our data processing activities where you consider that:
- Personal Information is inaccurate
- our processing of your Personal Information is unlawful
- where we no longer need the Personal Information but you require us to keep it to enable you to establish, exercise or defend a legal claim
- where you have raised an objection to our use of your Personal Information
- Request a copy of certain Personal Information that you have provided to us in a commonly used electronic format.
- Object to our processing of your Personal Information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your Personal Information
- Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
If you wish to exercise any of your above rights, please reach out to us by emailing us at: email@example.com