Last updated on April 22, 2020
When we use the term “Personal Information” we mean any information that we collect in connection with a GNG Program that would allow someone to identify you or contact you, such as your full name, address, e-mail address, telephone number, username or photograph. When we use the term “Additional Information”, we mean any information that we collect about you in connection with your participation in a GNG Program other than Personal Information, including through our website or the website of any GNG Program (each, a “Website”). Additional Information may include, but not be limited to, (i) usage information and details about how you use the software and services made available to you as part of a GNG Program, (ii) technical information provided as part of your access and use of a Website (e.g., browser and device information, access times and other relevant statistics, pages viewed and content searched and identifiers associated with cookies); and (iii) content you provide us in connection with a GNG Program. Personal Information and Additional Information shall be collectively referred to as “Information”.
1. HOW WE USE AND COLLECT INFORMATION
Registration. When you register for a GNG Program, we will require you to provide certain Information, which may include, but not be limited to, your full name, country, email address, telephone number, date of birth, etc. This Information will be used to administer your participation in such GNG Program. If an account is or will be required in connection with your participation in a GNG Program, this information will also be used to administer and verify access to your account.
Program Features. We use your Information to provide you with the applicable GNG Program that we are improving all the time. We use your Information to (i) develop, operate, improve, deliver, maintain, and protect the applicable GNG Program; (ii) personalize the applicable GNG Program and contextualize your experience; (iii) enhance the safety and security of the applicable GNG Program; (iv) verify your identity and prevent fraud or other unauthorized or illegal activity; and (v) enforce our Terms and other policies. You therefore agree to provide us with whatever Information you create, submit, upload, send or transmit in connection with the GNG Program.
Communications. You may be presented with the opportunity to sign up to receive newsletters, email communications, or other communications from us in order for us to provide up-to-date information about GNG Programs, and to publicize and promote certain content, products and services offered by us or our business partners that we think may interest you. For details on how to “opt-out” from such communications, see Section 4 below (“Newsletters, Promotional Materials, Support Communications, etc.”). If an account is or will be required in connection with your participation in a GNG Program, we may also use your Personal Information to access your user account in order to respond to any technical support requests. When you initiate any communications with us, whether it be as part of a general query, a support request, or any other communication via a Website or by email, you consent that we will use your Personal Information and whatever information you volunteer, to communicate with you and to best assist you with your questions or needs.
Data Collection and Analytics. Our Websites include features that automatically collect Additional Information regarding your access and use of such Website. This Additional Information is used to assist us in keeping track of your preferences, create a more tailored user experience and better serve your particular interests and needs.
A Website may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, analytics and advertising service providers and other third parties to, for example, analyze and track data, determine the popularity of certain content, and better understand your online activity. They may also be used to serve advertisements on a Website, facilitate targeting of advertisements or measure and analyze advertising effectiveness or traffic on a Website.
2. SHARING AND DISCLOSURE OF INFORMATION
Service Providers. We may disclose your Personal Information to third parties, business partners, service providers, vendors, and affiliates (“Service Providers”) for the purpose of administering, maintaining and supporting the applicable GNG Program and operations in connection therewith. We use Service Providers to efficiently provide the full range of content, activities and services we bring you and we also disclose your Information to such Service Providers for the purpose of providing services to us in connection with the applicable GNG Program. These Service Providers may store some Information on their servers, but they may only use your Personal Information to provide us with a specific service and not for any other purpose and agree to keep such Personal Information secure and confidential.
Business Transfers and Sale. If we are involved in a merger, acquisition, asset sale, financing, reorganization, liquidation, bankruptcy, or other transaction that includes the transfer of all or a some portion of our assets, your Information may be sold, transferred or shared as part of that transaction.
3. RETAINING YOUR INFORMATION
User Account. If an account is or will be required in connection with your participation in a GNG Program, we will retain the Personal Information submitted for your user account as long as you maintain an account associated with our Program or as is necessary to allow you to participate in such GNG Program, or future email communications from us.
Additional Information. We will maintain and use Additional Information as long as is legally permissible in order to provide and improve a GNG Program. You acknowledge and agree that we have the right to use and display any photographs (including those depicting Personal Information) uploaded in connection with Additional Information as part of a GNG Program.
Legal Obligations. Your Personal Information will be retained as necessary to comply with any applicable federal, state or local law and to conduct legitimate business activities, obligations, resolve disputes, and to enforce all of our agreements.
4. USER CHOICE; DELETING PERSONAL INFORMATION
This section sets out the procedure for accessing, viewing, modifying and deleting your Personal Information. You always have the right to ask to access and correct the Personal Information you have provided and generally you may review, update or delete certain information collected by us in connection with a GNG Program at any time by following the instructions below.
Accessing, Modifying, and Deleting Your User Account. If you have registered for a GNG Program (or, if applicable, created a user account) and you need to access, view, correct, modify 11or delete the Personal Information associated with your participation in a GNG Program, you can do so by emailing us at email@example.com and requesting that your Personal Information be deleted. If an account is or will be required in connection with your participation in a GNG Program, we may also delete your account and most of the Information we have collected about you if your account is inactive for a long period of time (but we will try to contact you prior to an account deletion initiated by us). Keep in mind that, we cannot promise that deletion will occur within a specific timeframe. There may be legal requirements to store your Information and we may need to suspend those deletion practices if we receive valid legal process asking us to preserve such Information or if we receive reports of abuse or other Terms violations. Finally, we may also retain certain Information in backup for a limited period of time or as required by law.
Portability. If you would like to obtain a copy of the Personal Information you have shared with us in connection with a GNG Program at any time, you can do so by emailing us at firstname.lastname@example.org. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access, update or download yourPersonal Information. We may also reject your request to do so for a number of reasons, including, for example, that the request risks the privacy of other users or is unlawful.
Newsletters, Promotional Materials, Support Communications, etc. If you consented to receiving such communications, you can unsubscribe by either following the specific instructions included in such communications or you may “opt-out” of receiving marketing and promotional emails from us at any time by sending an email to us at email@example.com detailing your request. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt out or unsubscribe cannot be retrieved or rescinded by us unless required by applicable law, and you cannot retroactively opt out or unsubscribe with respect to such third parties through us. We may also have features that allow you to submit information, questions or feedback to us. In those instances, we may retain your emails and other information you submit to us for our internal purposes, and to help us and our Service Providers serve you better.
While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information. However, regardless of our efforts, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. We also limit access to your Personal Information by our own employees, contractors, Service Providers and those individuals who are authorized for the proper handling of such Personal Information. We request that our Service Provider follow similar standards of security and confidentiality.
6. THIRD-PARTY CONTENT AND INTEGRATIONS
As part of a GNG Program, as well as your use of a Website, you may be provided with links to other websites or access to third-party content, resources, software, services or features, including services we jointly offer with such third-party. For example, table conversations as part of certain GNG Programs are currently hosted on a third-party web conferencing platform and are scheduled using a third-party scheduling tool. Through these links and third-party content or services, you may be providing Information (including Personal Information) directly to the third party, us, or both. We encourage you to review the privacy policies of every third-party service that you visit or use, including those third parties you interact with in connection with a GNG Program, to find out how those third parties collect and use your Personal Information.
We comply with the Children’s Online Privacy Protection Act (“COPPA”) to ensure the online safety of children. We do not collect Personal Information about children under the age of 13 without a parent or guardian’s consent. When a GNG Program is offered by a school, COPPA allows teachers and school administrators to provide consent for the collection of Personal Information from children. The school should notify parents and guardians of participation in a GNG Program.
In any instance that we collect Personal Information from a child under 13, we will (i) not disclose the such Personal Information to third parties except as required for the functionality of the GNG Program, (ii) provide parents and guardians with access to their child’s Personal Information to review or have deleted, (iii) give parents and guardians the option to cease collection of their child’s Personal Information, and (iv) retain collected Personal Information only so long as reasonably necessary to facilitate participation in a GNG Program, ensure the security of our users and the GNG Programs, or as required by law. In the event we discover we have collected Personal Information from a child in a manner inconsistent with COPPA’s requirements, we will either delete such Personal Information or immediately seek the parent or guardian’s consent for that collection.
9. PARTICIPANTS IN THE EUROPEAN UNION
If you’re a participant in a GNG Program residing in the European Union (“EU”), you should know that GNG is the controller of your Personal Information. Here is some additional information we would like to bring to your attention:
Bases for Using Your Information. Your country only allows us to use your Personal Information when certain conditions apply. These conditions are called “legal bases” and we typically rely on one of four: (i) the contract you’ve entered into with us, (ii) a legitimate interest in using your Information, (iii) your consent; or (iv) any legal obligation.
Your Right to Object. You have the right to object to our use of your Personal Information. If there are types of Information you don’t agree with us processing, you can contact us at firstname.lastname@example.org.
Complaints. If you’re based in the EU, you can always file a complaint with the supervisory authority in your member state.
11. CONTACT US