We take your privacy very seriously. To the extent we collect, use, or otherwise store personal information about you, we may be subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom). Please read this privacy notice carefully.
Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California or federal law.
- Geolocation data
- Professional or employment-related information
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
This personal information may be required to provide access to certain resources available on the Database to you.
How Your Personal Information is Collected. We would collect most of this personal information directly from you—in person, by telephone, text or email and/or via the Database itself.
How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about the Database, including exclusive offers, promotions or new resources or services. We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal information with the utmost respect and never sell it to other organizations for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us at EMAIL ALIAS. We may ask you to confirm or update your marketing preferences if you instruct us to provide further resources or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We May Share Your Personal Information With. We may share personal information with:
- Service providers we use to help deploy the Database and provide access to you;
- Other third parties who help us run the Database, such as website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
Where Your Personal Information is Held. Information may be held on our servers, by service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
How Long Your Personal Information Will Be Kept. To the extent we hold any personal information of yours, we will keep your personal information while you have an account with us (for example, via the Inclusivity Reader Database) or while we are providing Database access to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this notice.
Your Rights Under the GDPR.
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|Right to Object||The right to object:- at any time to your personal information being processed for direct marketing (including profiling);- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.
Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know:· The categories of personal information we have collected about you;· The categories of sources from which the personal information is collected;· Our business or commercial purpose for collecting or selling personal information;· The categories of third parties with whom we share personal information, if any; and· The specific pieces of personal information we have collected about you.· Please note that we are not required to:· Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;· Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or· Provide the personal information to you more than twice in a 12-month period.|
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; andThe categories of personal information that we disclosed about you for a business purpose.You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.|
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:· Delete your personal information from our records; and· Direct any service providers to delete your personal information from their records.· Please note that we may not delete your personal information if it is necessary to:· Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;· Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;· Debug to identify and repair errors that impair existing intended functionality;· Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;· Comply with the California Electronic Communications Privacy Act;· Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;· Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;· Comply with an existing legal obligation; or· Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.|
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:· Deny goods or services to you;· Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;· Provide a different level or quality of goods or services to you; or· Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.|
How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Notice, please email us at EMAIL ALIAS. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. If you choose to contact directly by email, you will need to provide us with:
- Enough information to identify you (e.g., your full name);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
Changes to This Privacy Notice. We may change this privacy notice from time to time–when we do, we will inform you via the Database.