Privacy Policy
Last Updated: 13 April 2020
Introduction
Human Rights Pulse, a service of Just Atonement Inc. (“HRP”) respects your privacy. This privacy policy explains how HRP handles online information practices as it applies to our website, www.humanrightspulse.com. We hope to share how HRP collects, uses, and discloses personal information as well as explain the choices and rights individuals have regarding their personal information. Capitalised terms not otherwise defined herein have the meaning ascribed to them in the HRP Terms of Service.
Here is the data we collect from you when you visit the site.
Information collected directly
We collect personal information directly from you—such as your name, phone number, picture of your face, email address, and business information—when you contact us directly such as by filling out our contact form, providing that information to us over email, signing up for our communications services (such as Slack) or subscribing to our mailing list.
Information collected automatically
Through the use of cookies, log files, pixel tags, local storage, and other tracking technologies, our server captures information regarding your operating system, the type of computer you are using, the type of browser you are using, your IP address, the URL link you may have come from, the search term you may have used to land on our website, the time and date you came to our website, the content on the website you are looking at, and anything you might download (the “Captured Data”) .
Both the information we capture directly as well as the Captured Data is the “Online Data”.
Here is how we use your Online Data
We only process your Online Data occasionally and incidentally as part of our core business practices. As a general matter, we use your Online Data to (i) respond to any inquiries you send to us through our website, and (ii) to better manage and run the website. Specifically, we use the the Online Data as follows:
Website and business operations
To provide and operate our website including display, language, and device preferences and to better understand how users access and use our website. We may also use the information you provide to respond to your inquiries or requests. We also use the information to permit you to potentially access third party services that we use as part of the website, such as Slack.
Content Development
We use your data to improve and administer more relevant content. For example, we might notice that people are using certain search terms that tend to point them to our website. We might use that information to create content around those areas. We use your name and photo to identity people as authors of various Submissions.
Legal Obligations
We may have to use your personal information to comply with the law, legal proceedings, or other legal obligations. For example, we may disclose information in response to subpoenas, court orders, and/or lawful requests by regulators and/or law enforcement. We may also use your data to protect and defend our legal rights.
Marketing and Promotion
For direct marketing purposes, including to send you newsletters, client alerts, and information we think may interest you. We will only send you these messages if you opt-in to receive them. If you no longer with to receive marketing-related emails from us going forward, you may opt-out of receiving emails by click the “Unsubscribe” link at the bottom of the email or by contacting us using the information provided below.
Risk Protection and Mitigation
To protect the site and business operations against fraud, unauthorized access, and misuse We might notice that data we are monitoring indicates a DDOS attack, for example. We would conceivably use automatically collected information to enact defenses and to protect the website.
Cookies
We use cookies to enhance your browsing experience. Read more about our use of cookies through our Cookie Policy.
How we share your Online Data
HRP may share or disclose some personal information from the Online Data with the following categories of providers and for the reasons detailed below:
· To our internal and external advisors and auditors.
· To third-party data processors we use (such as our hosting platform, website platform, communications platforms such as Slack, and data storage platforms), in order to run and operate the website and enhance the user experience. The Online Data may be processed and shared with those platforms or programs as it goes through their systems. Each data processor has in place an applicable data processing agreement (“DPA”) which binds the use of personal information in conformity with applicable law.
· Personally identifiable information you provide over email or through the forms on the website will be processed through our email system, our email host provider, our internet host provider, and our website host provider.
· To our vendors who provide services to help run our business (such as banks, accounting firms, and third-party software services).
· Information may be shared with law enforcement, regulators, or other legal entities in order to comply with a judicial proceeding, a subpoena, a request from a regulator, or other legal obligation.
· To third parties engaged in the services we provide to clients such as counsel, arbitrators, and mediators (only with your express written consent).
· To necessary parties if we believe that such disclosure is necessary to otherwise protect and/or defend our rights, property, safety or that of our clients or other users of the website.
Other than with your express written consent, we will not and will never sell any of your Online Data. The only exception to this is if we transfer such information to an affiliate entity, under the control or common control of Just Atonement Inc.
The security and retention of your online data is as follows
We take reasonable and appropriate steps to protect your Online Data, including the Captured Data, against unauthorized access, improper use or disclosure, or accidental loss. However, we cannot provide a guarantee that the measures we have taken are sufficient to protect any such information.
We will retain your Online Data for the period necessary to fulfill the purposes outlined in this privacy policy. We will retain certain information in accordance with law and regulatory requirements.
Data subject rights
We respect your rights and control over your personal data. You may exercise any of the following rights by contacting our Global Data Privacy Officer as detailed below. Please note you may ask you to verify your identify before taking further action on your request.
a. Right of Access - the right to be informed of and request access to the personal data we process about you;
b. Right of Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
c. Right to Erasure - the right to request that we delete your personal data;
d. Right to Restrict Processing - the right to request that we temporarily or permanently stop processing all or some of your personal data;
e. Right to Object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
f. Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service;
g. Right to Lodge a Complaint - You may have the right to complain to a relevant Data Protection Authority if you believe your personal information, including the Collected Data, has been collected or used in breach of privacy rules, or this Privacy Policy. If you are located in the European Union, you should contact the Data Protection Authority in the country in which you are located. If you are located in the United Kingdom, you should contact the Office of the Information Commissioner in the United Kingdom, at www.ico.org.uk.
Legal basis of processing
It is necessary for us to use your personal information:
· In order to perform our obligations according to any contract that we may have with you.
· As a legitimate interest to ensure that we provide our services in the best way possible.
California residents
California Civil Code Section § 1798.83 permits users of our sites or services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information provided below.
We do not respond to “Do Not Track” (DNT) signals.
Changes to this privacy policy
We may update this Privacy Policy to reflect changes to our data practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the changes becoming effective. We will also detail below the changes that have been made.
How to contact our global data privacy officer and data controller
Your privacy is important to us, and so, Just Atonement Inc. Executive Director, Dave Inder Comar, is our Global Data Privacy Officer. If you have any questions or concerns about this Privacy Policy or the data we collect, contact us at info@humanrightspulse.com
For residents of the EEA, the data controller for this website is: Just Atonement Inc., 1832 Buchanan Street, Suite 201, San Francisco, California, 94115, United States of America.
Thank you for reading through our Privacy Policy!
Previous Changes to Privacy Policy
13 April 2020:
Edits to the policy to cover the use of Slack and communications platforms used by HRP
Clarified that personal photos used as part of any Submission are also covered by the policy.
1 December 2019: original Privacy Policy released.