SECTION 6.01 INTRODUCTION
(a) Provisions of this Article 6 provide supplemental information with respect of personal information and individuals (who interact with Open Longevity by means of use of the Websites and the Services) located in the European Union (“EU
”) and the European Economic Area (“EEA
(a) Open Longevity is the personal data controller in respect of your personal information collected and used through your use of the Websites and the Services. SECTION 6.03 COLLECTION OF INFORMATION
(a) We collect and use personal information about you in the course of providing access to the Websites and providing the Services. The information that you provide to us may include the following:
- Contact Information: name, mailing address, email address and telephone number;
- Professional Information: organization name, your title within the organization, industry type, status, and other business information about the organization;
- Account Information: contact information as set forth above, username, password, and any other information you choose to include in your profile;
- Donation Information: billing address, email address, information about the donation (charity donating to, the amount of the donation), payment information, records of donations, receipts of donations;
- Payment Information: payment card number (credit or debit card), expiration date, or other financial account number and account details;
- Marketing Preferences, Marketing Activities and Customer Feedback: Marketing preferences, or responses to voluntary customer satisfaction surveys. To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications;
- Attendance Information: registration information, record of attendance at a webinar or another event; contact information;
- Other Information You Provide to Us: for example, if you write a review of our Services or provide other information to us in the course of your use of our Websites or Services.
(b) The personal information above may be provided:
- in the course of communications between you and us (including by phone, email, chat, any or otherwise);
- when you register for an account and/or fill out an application form;
- when you inquire about our Services;
- when you make a donation;
- when you register to attend one of our webinars, meetings or other events;
- when you sign up for our e-newsletter or other materials;
- when you post on our Websites’ publicly available features, such as online blogs; and
- when you report a problem with our Websites or Services.
(c) We may also collect personal information about you through your use of the Websites and the Services. This information includes online activity information and technical information about your usage activities, to the extent that such information constitutes personal information. We collect technical information automatically through your electronic device, such as your IP address (i.e. your computer’s address on the internet), operating system type (Windows or Mac) and version, internet browser type and version, internet service provider (ISP), and language. We also collect information about your use of our Websites, e.g., dates and times of log-in and out to your account, time spent on pages and the pages visited. We use this information to ensure that the Websites and the Services function properly.
(d) We may also receive personal information from other sources, such as:
SECTION 6.04 COOKIES
- any other websites we operate or other services we provide (if you use any of them);
- information we obtain from publicly available sources, e.g., via social media resources like Facebook or LinkedIn;
- information from public records in order to conduct due diligence or for conducting fraud prevention checks or to supplement your profile (i.e., zip code);
- information from your employer if you are using our Services through an employer-run program;
- information from corporate partners if you are using our Services through a corporate partner program.
(b) We use Google Analytics, a web analytics service provided by Google, Inc. For more information about Google Analytics, or to opt-out of Google Analytics, please go to Google Analytics Opt-Out Settings page here https://tools.google.com/dlpage/gaoptout
(d) We use third-party vendors, including Google, in order to show ads on third-party sites across the Internet.
(e) We, along with third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to our Websites and to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Website.
(f) We use data from Google Analytics Demographics, Interest Reporting, and third-party audience data to help us understand how people find and use our Website.
(g) Visitors can opt-out of Google Analytics for Display Advertising, customize Google Display Network ads using Google’s Ads Settings page.
(h) Cookies do not allow the Websites to access personal information that you haven’t already provided to us.
(j) You can refuse to accept the cookies we use by adjusting your browser settings. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Websites and or our Services.SECTION 6.05 USE OF INFORMATION
(a) We use your personal information in the course of providing access to the Websites and providing the Services. In particular, your personal information may be used by us, our employees, service providers, and disclosed to third parties for below purposes.
(b) For each of these purposes, we have set out the legal basis on which we use your personal information:
- To communicate with you and other individuals: For our legitimate business purposes (i.e., to procure access to the Websites and the Services);
- To procure access to the Websites and the Services: For our legitimate business purposes (i.e., to procure access to the Websites and the Services), and depending on the circumstances, to perform an agreement between you and us;
- To process your donations and communicate with you: For our legitimate business purposes (i.e., to procure access to the Websites and the Services), and depending on the circumstances, to perform an agreement between you and us;
- To notify you about changes to the Websites or the Services: For our legitimate business purposes (i.e., to procure access to the Websites and the Services);
- To audit and monitor the use of the Websites: For our legitimate business purposes (i.e., to procure access to the Websites and the Services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law (e.g., in relation to our use of certain cookies);
- To improve the quality of the Websites and the Services: For our legitimate business purposes (i.e., to procure access to the Websites and the Services);
- To manage complaints, feedback and queries: For our legitimate business purposes (i.e., to procure access to the Websites and the Services);
- To carry out market research and analysis: For our legitimate business purposes (i.e., to procure access to the Websites and the Services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law;
- To carry out satisfaction surveys and analysis: For our legitimate business purposes (i.e., to procure access to the Websites and the Services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law;
- To provide you with information about the Services we offer (including details of any services which we believe may be of interest to you, including notifying you of opportunities for future donations) in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences: For our legitimate business purposes (i.e., to procure access to the Websites and the Services). We may request your consent in circumstances where a legal justification over and above legitimate interests is required by applicable law;
- To compile aggregate statistics about how our Websites and Services are being used: For our legitimate business purposes (i.e., to procure access to the Websites and the Services);
- To comply with any legal or regulatory obligations (including in connection with a court order and to meet our reporting requirements): For our legitimate business purposes and for compliance with our legal obligations;
- To enforce or apply the agreements concerning you (including agreements between you and us): For our legitimate business purposes and for compliance with our legal obligations.
(c) We may be required to obtain your personal information to comply with our legal requirements, to enable us to fulfill the terms of our agreement with you or in preparation of us entering into an agreement with you. If you do not provide the relevant personal information to us, we may not be able to procure access to the Websites and the Services to you.
(d) Where we rely on our legitimate business interests or those legitimate interests of a third party to justify the purposes for using your personal information, this will include:
SECTION 6.06 DISCLOSURE OF INFORMATION
- pursuit of our activities and objectives, or those of a third party;
- compliance with applicable legal and regulatory obligations and any codes of conduct;
- improvement and development of our operations and service offering, or those of a third party; or
- protection of our directors, employees and customers, or those of a third party.
(a) We may disclose and transfer your information by means as set forth in Articles 4 and 5 above.SECTION 6.07 PROTECTION OF INFORMATION
(a) We take reasonable security precautions to protect the personal information that we collect and you provide to us. We use industry-accepted tools, including technology protocols, to protect against the loss, misuse, and unauthorized alteration of the information we collect. We help to protect your information by working with our vendors who provide a secure and safe environment for credit card donations. Please remember that the safety and security of your information also depends on you. Where we have given you (or you have chosen) a login ID or password to access certain of our Services or areas of the Websites, you are responsible for keeping such ID and/or password confidential. We ask that you not share such information with anyone or allow anyone to sign in using your credentials.
(b) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Websites and any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access.SECTION 6.08 RETAINING OF INFORMATION
(a) We will retain your personal information for as long as is necessary for purposes for which it was collected. The precise period will depend on the reason why it was collected. Those periods are also based on the requirements of applicable data protection laws, applicable legal and regulatory requirements and periods relating to the commencement of legal actions.SECTION 6.09 GDPR RIGHTS
(a) Open Longevity undertakes to respect the following data protection rights available to you under the EU General Data Protection Regulation (GDPR):
- Right of Access to Your Personal Information: you have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions;
- Right to Rectify Your Personal Information: you have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete;
- Right to Erasure Of Your Personal Information: you have the right to ask that your personal information be deleted in certain circumstances, e.g., (i) where your personal information is no longer necessary in relation to the purposes for which it is being collected or otherwise used; (ii) if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information; (iii) if you object to the use of your personal information (as set out below); (iv) if we have used your personal information unlawfully; or (v) if your personal information needs to be erased to comply with a legal obligation;
- Right to Restrict Use of Your Personal Information: you have the right to suspend our use of your personal information in certain circumstances, e.g., (i) where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead; (iii) we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims; or (iv) you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection;
- Right to Data Portability: you have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of an agreement, and when the use of your personal information is carried out by automated (electronic) means;
- Right to Object to Use of Your Personal Information: you have the right to object to the use of your personal information in certain circumstances, e.g., (i) where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party); and (ii) if you object to the use of your personal information for direct marketing purposes;
- Right to Withdraw Consent: you have the right to withdraw your consent at any time where we rely on consent to use your personal information;
- Right to Complain to the Relevant Data Protection Authority: you have the right to complain to the relevant data protection authority where you think we have not used your personal information in accordance with data protection law.