Last updated May 1 2020
1. Our Principles ALBA has designed this policy to be consistent with the following principles:
● Privacy policies should be human readable and easy to find.
● Data collection, storage, and processing should be simplified as much as possible to enhance security, ensure consistency, and make the practices easy for users to understand.
● Data practices should meet the reasonable expectations of users.
2. Information We Collect We collect information in multiple ways, including when you provide information directly to us; when we passively collect information from you, such as from your browser or device; and from third parties.
Information You Provide Directly to Us
We will collect any information you provide to us. We may collect information from you in a variety of ways, such as when you: (a) create an online account, (b) make a donation or purchase, (c) contact us or provide feedback, (d) upload your creative work or images, (e) subscribe to our newsletter, or (f) apply for a job at ALBA. This information may include but is not limited to your name, email address, phone number, mailing address, payment information, photo, geographic location, and your social media handles. We may also collect additional demographic and other information about you (e.g., age and other preferences), and the provision of this information to us by you is optional.
Information that Is Automatically Collected
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze (a) device information such as IP addresses, location information (by country and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile device carrier information, and (b) information related to the ways in which you interact with the Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c) understand the web pages of the Services you have visited and the referral sites that have led you to our Services; (d) enhance your user experience by delivering content specific to your inferred interests; (e) perform searches and analytics; and (f) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. We may also use tracking technologies in our license buttons and/or icons that you can embed on other sites/services to track the website addresses where they are embedded, gauge user interaction with them, and determine the number of unique viewers of them. If you receive email from us (such as the ALBA newsletter, campaign updates, or other ongoing email communications from ALBA), we may use certain analytics tools, such as clear GIFs, to capture data such as whether you open our message, click on any links or banners our email contains, or otherwise interact with what we send. This data allows us to gauge the effectiveness of our communications and marketing campaigns. As we adopt additional technologies, we may also gather additional information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Information from Third Parties
We may also collect information about you or others through third parties. To the extent permitted by law, we may also collect information from third parties, including public sources, social media platforms, and marketing and market research firms. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information about an individual’s employer, information to verify identity or trustworthiness, and information for other fraud or safety protection purposes.
3. How We Use Your Information We may use the information we collect from and about you to:
● Fulfill the purposes for which you provided it;
● Provide and improve the Services, including to develop new features or services, promote ALBA community collaboration, take steps to secure the Services, and for technical and customer support;
● Fundraise, accept donations, or process purchases of ALBA merchandise;
● Host events and programs;
● Send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed;
● Process and respond to your inquiries or to request your feedback;
● Conduct analytics, research, and reporting, including to synthesize and derive insights from your use of our Services;
● Evaluate job candidates during our hiring process;
● Comply with the law and protect the safety, rights, property, or security of ALBA, the Services, our users, and the general public; and
● Enforce our Master Terms, including to investigate potential violations thereof.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes.
4. When We Disclose Your Information We may disclose and/or share your information under the following circumstances:
● Service Providers. We may disclose your information with third parties who perform services on our behalf, including without limitation, event management, candidate selection, marketing, customer support, data storage, data analysis and processing, and legal services.
For example, when you apply for a job, or to be selected to participate in one of our learning programs, ALBA may share that information with the individuals designated to select participants in, and help manage, those programs, which may include people not employed by ALBA.
Or, when you register for an event, we may share your information with vendors, third party contractors, partner organizations, and volunteers for the purpose of organizing and running the event and related activities.
● Business Transfers. As we continue to develop our business, we may engage in certain business transactions, such as the transfer or sale of our assets. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of ALBA’ assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
● Affiliated Companies. We may disclose your information with current or future affiliated companies.
● Consent. We may disclose your information to any third parties based on your consent to do so.
● Aggregate/De-identified Information. We may disclose de-identified and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others.
o Once you are an ALBA user, we may provide you with a public profile page, editable by you, and pre-populated with certain information you provided in your application such as your name, areas of interest, images or other content you upload, which will be publicly displayed to anyone who visits the site while logged in with their ALBA ID. Other information contained in your profile such as your biographical information, email address, languages spoken, country of residence, social media account information, or URL details will be displayed only to ALBA.
5. Legal Basis for Processing Personal Data The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose information that can be directly linked to or used to identify you. To the extent those laws apply, our legal grounds for processing such information are as follows:
● To Honor Our Contractual Commitments to You. Much of our processing of information is to meet our contractual obligations to provide services to our users.
● Legitimate Interests. In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, these include: ○ Customer service ○ Marketing, advertising, and fundraising ○ Protecting our users, personnel, and property ○ Managing user accounts ○ Organizing and running events and programs ○ Analyzing and improving our business ○ Managing legal issues We may also process information for the same legitimate interests of our users and business partners.
● Legal Compliance. We may need to use and disclose information in certain ways to comply with our legal obligations.
● Consent. Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent; in accordance with applicable law.
6. Online Analytics We may use third-party web analytics services (such as Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section above will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. 7. Your Choices and Data Subject Rights You have various rights with respect to the collection and use of your information through the Services. Those choices are as follows:
● Email Unsubscribe – You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of each newsletter or by emailing firstname.lastname@example.org with your request.
● Fundraising Analytics – You may opt out of ALBA’s fundraising analytics activities by contacting email@example.com with your request.
● Account Preferences – If you have registered for an account with us through our Services, you can update your account information or adjust your email communications preferences by logging into your account and updating your settings.
● EU Data Subject Rights – Individuals in the European Economic Area (“EEA”) and other jurisdictions have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold certain information about them, to access such information, and to obtain its correction or deletion in appropriate circumstances. You may have the right to object to our handling of your information, restrict our processing of your information, and to withdraw any consent you have provided. To exercise these rights, please email us at firstname.lastname@example.org with the nature of your request. You also have the right to go directly to the relevant supervisory or legal authority, but we encourage you to contact us so that we may resolve your concerns directly as best and as promptly as we can.
9. Security Measures We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
10. Children The Services are intended for users over the age of 18 and are not directed at children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, or personal data (as defined by the EU GDPR) from children under the age of 16, we will take reasonable steps to delete it as soon as practicable.