Guidebook complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. Guidebook has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Guidebook’s certification, please visit https:// www.privacyshield.gov. Additionally, Guidebook may protect information through other legally valid methods, including international data transfer agreements.
This Policy applies to all Guidebook’s operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield and any additional subsidiary, affiliate, or branch of Guidebook that we may subsequently form.
3. TRANSPARENCY/NOTICE—TYPES of Personal 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 Guidebook and the requirements of applicable law. Some of the ways that Guidebook may collect Personal Information include:
- You may provide Personal Information directly to Guidebook through interacting with the Services, participating in surveys, during events such as trade shows, and requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
1. Types of Personal Information We Collect
Guidebook collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).
- If you are a Guidebook Customer, you may provide Personal Information when you register with us through the Site to create and manage Guides, such as your name, company name, email address, and “Payment Information” such as billing address and credit card information.
- When you download or use the Guidebook App, any Guide published there or elsewhere, and/or use a Guide through the Site, you may choose to provide Personal Information for your registration and/or profile as follows:
- Name, email, photo/profile image, Company, Position/Title, Gender, phone number, and/or website (“Profile Information”).
- Linked social media accounts such as Facebook, Twitter, Google+ and LinkedIn (“Social Information”).
- If, when you create an account with us, you may choose to login using certain social media accounts (Facebook, LinkedIn, Twitter, etc). In this case, we collect the login identifier and password from this account (“Social Logins”).
- We collect your Mobile ID when you download the Guidebook App or a branded Guide app.
- If your device enables location services for the Guidebook App, we will collect information about your location when you use the App.
- You may send messages to other End Users or connect with them, in which case we will collect records and data reflecting your interactions with the other users.
- You may be asked, but not required, to complete surveys about your use of the Guidebook App. Note that this information is treated like Profile Information for purposes of this policy.
- This Section describes the information that we may collect from Visitors. To the extent you are a Guidebook Customer or an End User and visit the Site or use the Guidebook App, this Section will apply to you as well:
- If you contact us by email or by filling-out a registration form, we may keep a record of information you provide, such as contact information and correspondence.
- We will collect Usage Data reflecting your behavior on the Site.
- We may use session and persistent cookies, both first-party and third-party, to collect information about your visits to the Site.
Information Submitted Via Services. You agree that Guidebook is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Guidebook 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 or 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 Guidebook and to enhance our ability to provide you with information about our business, products, and Services.
2. How Guidebook Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
- We use your Personal Information to provide and improve the Services, process payments, complete your transactions, administer your inquiries, and contact you regarding account activities, new version and product offerings, or other communications relevant to the Services.
- If you interact with End Users through a Guide, for example by sending notifications or other information to them, we keep records of such messaging on our servers and use it in the operation of the Services.
- Your Guide may be accessible via search engines or similar services. You can keep your Guide private by adjusting your privacy settings.
- You Content will be visible to any End Users who download the applicable Guide, and Guidebook does not control the use or dissemination of Content in such cases by End Users, Visitors, or any third party. You are solely responsible for obtaining the consent of any data subjects whose Personal Information might be reflected in a Guide you create using the Services.
- We use Profile Information and Social information to populate a profile that is visible to other users of the Services. If you do not want other End Users to see this information, you should not input it into the Services. Guidebook cannot and does not control the actions taken by other End Users with information they can access through the Services.
- We use your location, if available, to tailor the Services to you and offer you more relevant information about your Guide, event, location, or other nearby users.
- We use information about your interactions with other End Users or Guide authors to operate and improve the services, deliver communications between you, and/or notify you that you have relevant information available to you to review within the Guide or Guidebook App.
- We use your Personal Information to communicate relevant information to you about the Services, your Guide, or the Guidebook App via email, to authenticate your access to the account (including by using Social Logins to authenticate your login to our own Guidebook App).
- It is possible that, because of the nature of the Guide you download using the Guidebook App or otherwise, certain potentially-sensitive information about you may be logged on our systems – for example: you download a guide relating to transgender advocacy or diabetes treatment.
- End Users can send a request to firstname.lastname@example.org to request that their Personal Information be deleted from our systems and not further shared with Guidebook Customers or other third parties. Note that this may require that you delete your Guidebook account and/or cease using one or more Guides.
- We may use information you input into a registration form or support contact to respond to your inquiries. In addition, we may use such details to send you information regarding the Site and/or the Services.
- We use Usage Information so that we can improve the Site, optimize its performance, and learn which parts are most popular to Visitors.
Marketing Guidebook Products and Services. Guidebook may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Guidebook may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Guidebook’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Anonymous and Aggregated Information Use. Guidebook may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Guidebook’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Guidebook may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Guidebook and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Guidebook’s Services may offer various tools and functionalities. For example, Guidebook allows you to provide information about your friends through our collaboration and invitation tools, which allow you to invite your friend or colleague to use our Services via email. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the collaboration or invitation link you request, but will not be used by Guidebook or any other Third Parties for any other purpose.
Other Uses. Guidebook may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
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 Site may not work properly.
- Session Cookies: We use these cookies to maintain your logged-in state on the site and offer login-restricted services to you, which facilitates and expedites your use of the Site. We also use these to recognize that you are a return visitor and/or a registered user.
- Persistent Cookies:
- Functional - These cookies allow our Site to remember choices or selections you make around functionality features (such as your user name, language selections or region within which you are located) and provide enhanced, more personal features. We also use these cookies to remember changes you make to other parts of our Site, which you may be able to customize from time to time. The information we collect via these cookies may be anonymized and they cannot track your browsing activity on other websites.
- Performance/Measurement - These cookies collect information about how Visitors use a Site, for instance which pages Visitors go to most often, and if they get error messages from webpages. These cookies do not collect information that identifies a Visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works.
- We may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of the Services.
Analytics. Guidebook uses third party analytics tools to review and analyze your behavior using a Guide, the Guidebook App, or the Site to help us operate, maintain and improve our products and services.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
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.
4. Third-Party Websites and Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Guidebook does 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.
Guidebook’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site 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.
We use Third-Party software development kits (“SDKs”) as part of the functionality of our Services. Third-Party SDKs may allow Third Parties, including advertisers, to collect your personal information to provide content that is more relevant to you. You may opt out of tracking by following the instructions below:
- Google Analytics. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
- Hot Jar. You can opt out of Hot Jar’s collection and Processing of data generated by your use of the Services by going to https://www.hotjar.com/legal/compliance/opt-out.
5. Third-Party Payment Processing
When you make purchases through the Services, we process your payments through a Third-Party application, Stripe. The Third-Party application may collect certain financial information from you to process a payment on behalf of Guidebook, including your name, email address, address and other billing information. When you enter Payment Information through the Site, you do so through an interface owned and operated by Stripe or our payment processing partner, to which you will be redirected automatically from Guidebook.
4. Human Resources Data
Guidebook collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
5. Onward Transfer—Guidebook May Disclose Your Information
1. Information We Share
We Use Vendors and Service Providers. We engage third parties, such as hosting companies, security auditors, or analytics providers, to help us analyze and improve our Services, and such vendors may have access to personal Information in our possession in the course of providing services to us. We require such vendors to agree to maintain the confidentiality of all of our confidential and/or proprietary business information, including your Personal Information, and to use such information solely for the purpose of providing services to us.
Business Partners. Guidebook may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Guidebook may also provide Personal Information to business partners with whom we may jointly offer products or 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 Guidebook. Guidebook 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 Guidebook provided them.
Privacy Shield. With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that Guidebook remain liable should its Agents Process Personal Information in a manner inconsistent with the Privacy Shield Principles.
Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Guidebook may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Guidebook related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). Guidebook may share information in its possession with government and law enforcement officials and private parties to enforce and comply with the law. We will access, preserve and disclose any Personal Information collected from Guidebook Customers, End Users and Visitors to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Guidebook or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. 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. INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by Guidebook may be transferred, Processed, and 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 Guidebook, you explicitly consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Guidebook’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
2. Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
3. Mobile devices
Guidebook may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Guidebook may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.
4. Human Resources Data
With regard to Personal Information that Guidebook receives in connection with the employment relationship, Guidebook will use such Personal Information only for employment-related purposes as more fully described above. If Guidebook intends to use this Personal Information for any other purpose, Guidebook will notify the Individual and provide an opportunity to opt out of such uses.
5. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6. Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
7. Rights of Access, Rectification, Erasure, and Restriction
Under Privacy Shield, you may inquire as to whether Guidebook is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of the Privacy Shield Principles.
EU and Swiss residents have the right to access personal data about them and to request the correction, amendment, removal or limitation of the use and disclosure of their personal data processed by Guidebook. Such requests should be sent by email to firstname.lastname@example.org or by regular mail to:
Attn: Security Department
340 Bryant Street, Suite 400
San Francisco, CA 94107
Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although Guidebook makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Guidebook is unable to provide access, including but not limited to: where the information contains legal privilege, 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 Guidebook determines 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, Guidebook will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
Guidebook is very concerned with safeguarding your information. We employ commercially reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. Unfortunately, no transmission of information over the Internet can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. We encrypt transmissions through our Services, including transmission of Personal Information, with Transport Layer Security (TLS), a cryptographic protocol recognized in the software industry as a reasonable secure method of internet transmission. In addition, our cloud service providers implement industry standard security measures to protect your Personal Information when in storage and/or at rest.
Your Payment Information, subject to any changes to our third party payment processor’s operations, is secured according the Payment Card industry Data Security Standards, Level 1.
Our employees are provided with context-specific access to our systems and your Personal Information, and are subject to contractual obligations to access and use your Personal Information only as required to deliver Services to you.
While our Services use cloud infrastructure, our cloud provider places technical and procedural safeguards in place to limit their access to any of our business information, including your Personal Information.
Any changes to the treatment of Personal Information are reviewed and approved by Guidebook management.
While we make it a practice to request restrictions on the onward transfer of your information from our vendors, we are not able to monitor or guarantee the compliance of third parties with our policies in each and every case.
By using the Site 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 Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. International Users
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 to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Children’s Privacy
Our Services are not directed to children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 13. 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 Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible and terminate the child’s account.
12. Redress/Compliance and Accountability
Attn: Security Department
340 Bryant Street, Suite 400
San Francisco, CA 94107
We will address your concerns and attempt to resolve any privacy issues within 45 days.
If you are an EU or Swiss citizen and feel that Guidebook is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact Guidebook at the contact information provided above.
In addition, Guidebook has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Program, and, with respect to Employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding Individual data to JAMS, a dispute resolution provider which has locations in the United States, visit https://www.jamsadr.com/eu-us-privacy-shield.
Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Guidebook’s compliance with the Privacy Shield.
13. Other Rights and Important Information
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, Guidebook will endeavor to comply with the law or contract.
2. California Privacy Rights California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes other than the reciprocal sharing of information with Guide authors.
3. Compliance This Policy shall be implemented by Guidebook and all its operating divisions, subsidiaries and affiliates. Guidebook has put in place mechanisms to verify ongoing compliance with Privacy Shield Principles and this Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.
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, Guidebook or to which Guidebook discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Guidebook or its subsidiaries worldwide.
“Mobile ID” means a unique, proprietary alphanumeric tag we create specifically to reflect your mobile device on our systems as a part of operating the Services, which is not known to any third party and is generated by a proprietary method we keep confidential.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”). This includes, but is not limited to, information that alone or when in combination with other information may be used to identify, contact, or locate you, such as: name, address, email address, IP Address, login credentials, profile information, or phone number, and excludes information that has been aggregated and/or anonymized so that it does not allow a third party to easily identify a specific individual.
“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2), choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities.
“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.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Guidebook or Guidebook’s Agents.
“Usage Information” is information reflecting usage of our Services through a web browser or mobile application, such as browser type, operating system version, click behavior, connection speed, which does not reflect the identity of any individual user.
15. Revision history and Contact
Initial Posting: April 25, 2011
Effective Date: Oct 17, 2018
Last Updated Date: Oct 17, 2018
Attn: Security Department
340 Bryant Street, Suite 400
San Francisco, CA 94107