2. Our Principles
André Costa 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 always meet the reasonable expectations of users.
3. Personal Information André Costa Collects and How it is Used
As used in this policy, “personal information” means information that would allow someone to identify you, including your name, email address, IP address, or other information from which someone could deduce your identity.
André Costa collects and uses personal information in the following ways:
Website and Fundraising Analytics: When you visit our Websites and purchase our products, André Costa collects some information about your activities through tools such as Google Analytics. The type of information that we collect focuses on general information such as country or city where you are located, pages visited, time spent on pages, heat-map of visitors’ activity on the site, information about the browser you are using, etc. André Costa collects and uses this information pursuant to our legitimate interest in enhancing the security and utility of our Services & Products. The information we gather and process is used in the aggregate to spot trends without deliberately identifying individuals, except in cases where you engage in a transaction with André Costa by purchasing a product. In those cases, André retains certain information about your visit to the Services pursuant to its legitimate interest in understanding its community of supporters for fundraising purposes, and this information is stored in connection with other personal information you provide to André Costa.
Note that you can learn about Google’s practices in connection with its analytics services and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
If you would like to opt out of André Costa’s analytics, please contact firstname.lastname@example.org with your request.
Information from Cookies: We and our service providers (for example, Google Analytics as described above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities. The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).
Events: When you sign up for an event hosted or supported by André Costa, you will be asked to provide some personal information, including your name, email address, and other information as needed. André Costa collects and uses this personal information pursuant to its legitimate interest in organizing and running the relevant event. We may share your personal information with vendors, third party contractors, partner organizations, and volunteers for the purpose of organizing and running the event and related activities.
Emails and Newsletters: When you sign up to receive updates from André Costa or otherwise subscribe to one of our mailing lists, you will be asked to provide some personal information. André Costa collects and uses this personal information pursuant to its legitimate interest in providing news and updates to, and collaborating with, its supporters and volunteers.
Email Analytics: When you receive communications from André Costa after signing up for the André Costa newsletter, campaign updates, or other ongoing email communications from André Costa, we may use analytics to track whether you open the mail, click on the links, and otherwise interact with what we send. You may opt out of this tracking by choosing to get plain-text emails from André Costa. André Costa collects and uses this personal information pursuant to its legitimate interest in understanding the interests of its community of supporters and volunteers in order to provide more relevant news and updates.
4. Retention of Personal Information
The majority of the personal information collected and used as explained in Section 3 above is aggregated and stored in a central database provided by a third party service provider. André Costa aggregates this data pursuant to its legitimate interest in having information stored in a single location to minimize complexity, increase consistency in internal practices, better understand its community of supporters and customers, and enhance the security of the data.
5. Access to Your Personal Information
You are generally entitled to access personal information that André Costa holds and to have inaccurate data corrected or removed to the extent André Costa still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information. If you wish to exercise any of these rights, please write to email@example.com explaining your request.
6. Disclosure of Your Personal Information
André Costa does not disclose personal information to third parties except as specified elsewhere in this policy and in the following instances:
André Costa may share personal information with our contractors and service providers in order to undertake the activities described in Section 3.
7. Security of Your Personal Information
André Costa has implemented reasonable security measures for personal information that we process against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.
8. Third Party Service Providers
Creative Commons uses many third party service providers in connection with the Services, including website hosting services and database management, and others. Some of these service providers may place session cookies on your computer, and they may collect and store your personal information on our behalf in accordance with the data practices and purposes explained above in Section 3.
9. Third Party Sites
10. Transferring Data to Other Countries
If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that when we use and share your data as specified in this policy, we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.
The products and services are currently hosted in the United States and the United Kingdom, which means your personal information may be located on servers in the United States and/or the United Kingdom, but this may change from time to time.
Data transferred from the European Union to the United States or outside the European Union will be made on the grounds of a certification to the E.U./U.S. Privacy Shield regime and/or a data transfer agreement based on the Standard Contractual Clauses approved of by the European Commission respectively, consistent with applicable data privacy requirements.
Effective Date: 15 November 2018