As a global organization, Omidyar Network is made up of multiple corporate entities. To avoid doubt, the terms “Omidyar Network,” “we,” and “us” include Omidyar Network LLC and our affiliates and subsidiaries. Omidyar Network, LLC is the entity which owns and operates the Website, but it shares data received with its affiliates and subsidiaries.
We are headquartered in the United States and have offices around the world. While servers for the Website are located in the EU, information you share through the Website will be processed in EU, US, and UK (and possibly in our other office locations around the world, a list of which is located here: https://www.omidyar.com/offices). As such, to the extent you provide any information to us through the Website, it may be transferred from your country of residence to our systems in those locations. By accepting this Policy through submitting your information to the Website, you are consenting to such a transfer.
1. INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect Personal /information include:
- You may provide Personal Information directly to us through interacting with Website (e.g., the newsletter subscription option).
- As you navigate the Website, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
Below are the ways in which we collect personal Information and how we use it.
1.1 TYPE OF INFORMATION WE COLLECT
We may collect Personal Information of visitors to the Website, and subscribers to our newsletter (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Website, or engage in certain activities such as requesting information, or contacting us directly, we may ask you to provide personal information such as your name and email address. What follows is a more detailed explanations of the ways in which you might interact or otherwise communicate with us:
- Interactions with Us: We may collect Personal Information from you such as your name and email address when you choose to engage with our Services, request information about our Services, register for our newsletter, request to receive technical support, or otherwise interact or communicate with us.
- Posting on the Site: We may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in or on those mediums, the Website will collect the information you provide in such submission, including any Personal Information. If you choose to submit content to any public area of the Website, such content will be considered “public” and will not be subject to privacy protections set forth in this Policy.
- Automatic Data Collection: We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet Protocol (IP) address, cookie identifiers, mobile carrier, MAC address, IMEI, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, and other actions taken through use of the Services such as preferences.
- Information Submitted Via Services. You agree that we are free to use the content of any communications submitted by you via the Services (e.g., on public forums or through our “contact us” portal), including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing and/or marketing Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store ora Social Networking Sites (“SNS”), we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Omidyar Network and to enhance our ability to provide you with information about our business, products, and Services.
1.2 HOW WE USE YOUR INFORMATION
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Services or Information Requested. We may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:
- Generally manage Individual information and Accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services;
- Contact you to answer requests for technical support.
- Administrative Purposes. We may use Personal Information about you for its administrative purposes, including to:
- Measure interest in our Services;
- Ensure internal quality control;
- Prevent potentially prohibited or illegal activities; and
- Enforce our Terms.
- Omidyar Network Services. We may use Personal Information to provide you with materials consistent with those for which you have requested or signed-up (e.g., our newsletter). We may provide you with these materials by email, but to the extent you request further information and provide further personal data, we may contact you by means such as phone or mail (as permitted by applicable law). To avoid doubt, we only intend to provide you with information and Services you request or as we are required to provide by law.
You may contact us at email@example.com at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in below.
- Research and Development. We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing Services or develop new Services.
- Other Uses. Omidyar Network may use Personal Information for which we have a legitimate interest, such as anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
1.3 COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Website may not work properly.
- “csrftoken”: This cookie is used on the Contact Us form to ensure the form is being submitted by the browser that originally requested the page. This helps to prevent automated systems from abusing the service. More information about how csrftokens work can be found here.
We do not use Google Analytics or any other analytics technologies on this Website.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. See also the section on “Do Not Track” below.
1.4 THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS, AND SOFTWARE DEVELOPMENT KITS
The Website may contain links to other websites and other websites may reference or link to our Website or other Services. These other domains and websites are not controlled by us, and we do not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Our Services may include publicly accessible blogs, community forums, or private messaging features. The Website and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
2. Onward Transfer
2.1 Information We Share
We may share your information as described in this Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) our legitimate business purposes; and (iv) in connection with the provision of the Website. We have executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with any information or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear along with Omidyar Network. Omidyar Network requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Omidyar Network provided it to them.
- Displaying to Other Users. If you post content in a public forum on the Website, it will be displayed on the Website for the public to see. To the extent you include Personal Information about yourself in that post, you will be making your Personal Information viewable to the general public.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Omidyar Network policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Website. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
2.2 Data Transfers
All Personal Information collected via or by us may be stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your Personal Information in these locations.
3. Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Omidyar Network’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting firstname.lastname@example.org.
3.2 Email Communications
If you receive an unwanted email from us, you can unsubscribe at any time by clicking the “unsubscribe” button in the email you received or by contacting us at email@example.com. We will process your request within a reasonable time after receipt.
We, directly or through our Services, maintain “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
4. Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether we are Processing Personal Information about you, request access to Personal Information, and ask that we correct, restrict, or delete your Personal Information. To do so, please send an e-mail to firstname.lastname@example.org and include your full name, email address, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although we make good faith efforts to provide Individuals with information about how we process their Personal Information, there may be circumstances in which we are unable to provide such information and access, including but not limited to: where the information is protected by legal privilege or is within the scope of an expected, imminent, or current legal matter; would compromise others’ privacy or other legitimate rights; where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question; or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
5. Data Retention
6. Security of Your Information
By using the Website or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website or the reason for which you submitted Personal Information. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending an e-mail to you. You may have a legal right to receive this notice in writing.
7. International Users
By using the Website, we will transfer data to the United States and other international locations. By choosing to visit the Website, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of the state of California, United States, and the adjudication of any disputes arising in connection with Omidyar Network or the Website will be in accordance with the Terms.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and other international locations and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
8. Children’s Privacy
The Site and Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and we do not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you are under the age of 18, you must have your parent’s permission to access the Site and Services. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
9. Redress/Compliance and Accountability
If you have any questions about our privacy practices or this Policy, please contact us by email at firstname.lastname@example.org. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
10. Other Rights and Important Information
10.1 Changes To Our Policy and Practices
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, we will endeavor to comply with the law or contract.
10.2 California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. We do not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Omidyar Network or to which Omidyar Network discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Omidyar Network or Omidyar Network’s Agents.
12. Revision history
Effective: May 1, 2019