Last Modified Date: November 30, 2021
For purposes of this Policy, “Personal Information” is information relating to an identified or identifiable individual. Personal Information does not include de-identified or aggregated information. To the extent permitted by law, Personal Information does not include publicly available information that is lawfully made available to the general public or information that is lawfully made available from government records.
1. Establishing a System for the Protection of Personal Information
The Foundation will take steps to ensure that our officers and employees understand the importance of the protection of Personal Information and establish a management system for the protection of Personal Information.
2. Personal Information Collected by the Foundation
In order to provide you with the benefits of using the Website and/or the Software, the Foundation collects certain information from you and your devices. When collecting your Personal Information, the Foundation will identify its purpose of use and collect such Personal Information through a lawful and fair manner. The Foundation relies on the following legal grounds for collecting and using your Personal Information subject to applicable data protection laws: our legitimate interest, performance of [the License Agreement] between the Foundation and you, or your consent where applicable. The Foundation may collect certain types of Personal Information about you in a variety of ways, depending on your interactions with us, as described further below.
Personal Information that You Provide to Us
- Contact information: Contact information includes information you provide when you sign up to download the Software or when you contact us for more information. Examples may include your name and email address.
- Software usage information: Software usage information includes information you provide when you download and/or use the Software. Examples may include your location information, health information, and other personal characteristics.
Information Collected from Your Browser or Device
The Foundation automatically collects your IP address or other unique identifier (“Device Identifier”) for the computer, mobile phone, tablet, or other device (“Device”) you use to access the Website and/or the Software. A Device Identifier is a number that is assigned to your Device, and we identify your Device by its Device Identifier. We, and our service providers, may use a Device Identifier to, among other things, administer the Website; help diagnose problems with our servers; analyze trends; and track your web page movements over time.
Information Collected Using Cookies and Other Tracking Technologies
The Foundation collects certain information through tracking technologies such as: cookies (data files placed on a Device when it is used to visit the Website and/or the Software), mobile analytics software, and pixel tags (transparent graphic images, sometimes called web beacons or tracking beacons, placed on a web page or in an email, which indicates that a page or email has been viewed). We, or our service providers, may place cookies or similar files on your Device for security purposes, to facilitate site navigation, and to personalize your experience.
Certain web browsers may provide an option by which you may request your browser to inform websites you visit that you do not wish your activities to be tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals.” The Website does not currently respond to Do Not Track Signals.
3. How the Foundation Uses Personal Information
The Foundation may use the Personal Information we collect from you for a variety of business or commercial purposes, such as:
- To communicate with you about the Foundation’s activities or to conduct a survey or gather information through a questionnaire;
- To provide the features and functionality of the Software to you;
- To provide you with technical support related to the Software;
- To develop and improve the Software and other products and services;
- For research or statistical analysis purposes;
- To engage in duties which are necessary to handle inquiries or provide services promptly;
- For any other purposes identified when obtaining the relevant Personal Information; and
- To comply with applicable laws and regulatory requirements, or as requested by government or regulatory authorities.
The Foundation may also share your Personal Information as disclosed at the time you provide your information, as set forth in this Policy and in the following circumstances:
- We may share your Personal Information with third parties that perform functions on our behalf, such as service providers that host or operate the Website, analyze data, store data on our behalf, or for other processing needs;
- We may share your Personal Information with third parties, or third parties may directly collect your Personal Information, with Institutional Review Board approval for Foundation research purposes;
- We may share your Personal Information with our affiliates primarily for business and operational purposes;
- We may transfer and disclose your Personal Information with third parties to comply with a legal obligation, when we believe in good faith that the law or a governmental authority requires it; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to the Website or the public; and
- In the event that the Foundation is involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be sold or transferred as part of that transaction.
3. Disclosure to Outsourcees
The Foundation may, in accordance with applicable laws and regulations, provide any Personal Information we collect from you to our outsourcees to the extent necessary for the purpose of use which was identified by the Foundation in advance. In such a case, the Foundation shall request the relevant outsourcee to handle the relevant Personal Information in a proper manner, and the Foundation will supervise the outsourcee in a suitable fashion.
4. No Sales
In the last twelve months, the Foundation has not sold your Personal Information to any third parties or disclosed your Personal Information to any third parties for their own direct marketing purposes.
The Foundation considers factors such as the nature of the information, the purpose(s) for which the Personal Information has been collected, relevant technical measures, and applicable legal requirements when determining the appropriate retention period for the Personal Information. The Foundation will keep your Personal Information only for as long as is necessary to achieve the purpose(s) for which the Personal Information was collected, or as otherwise required or permitted by applicable laws and regulations.
4. Consent to Processing and Transfer of Information
Given that the Foundation operates and delivers the Software globally, our use of your information necessarily involves the transmission of data on an international basis. If you are located outside of the United States, please be aware that information the Foundation collects may be transferred to and processed in the United States and other countries . By using the Website, the Software or providing us with any Personal Information, you (i) acknowledge that the Website and the Software are subject to the laws of the United States, (ii) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen (you may withdraw this consent at any time by contacting us at firstname.lastname@example.org but this might result in your inability to use the Website and the Software), and (iii) waive any claims that may arise under those laws.
The Foundation implements security measures designed to protect the confidentiality, integrity, and availability of Personal Information and to prevent unauthorized access, destruction, or disclosure of Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us; you visit the Website, download the Software, and provide us with your information at your own risk. If you have any questions about security, you can contact us at email@example.com.
6. Your Rights
The Foundation would like to maintain accurate Personal Information. If you would like to access, delete, or correct any of your Personal Information that we may have collected about you, you may make a request by contacting us at firstname.lastname@example.org. You might also have rights, in certain circumstances, to data portability, to object to, or to restrict the Foundation's processing of your Personal Information. Where the Foundation relies on your consent to process your Personal Information, you also have a right to withdraw your consent at any time by contacting us. You might also have a right to complain to your local data protection authority about the Foundation's use of your Personal Information.
At any time, you may choose not to receive marketing and promotional communications from the Foundation by (i) selecting the unsubscribe link in the communication that we send you or (ii) contacting us at email@example.com. Please note that even if you opt out, we may still send you a response when you contact us for other reasons related to your use of the Software.
8. Continuous Improvements
From time to time, the Foundation may update this Policy. If we do, we will update the date at the top of this page. If the changes are material, we may alert you to the changes in a more prominent way. By using the Website and/or the Software after these changes are made, you acknowledge and accept the revised version of the Policy.
If you have any comments or questions regarding this Policy, you can contact the Foundation at: