All capitalized terms not defined herein will have the meanings set forth in the Terms of Service. When we make a material update to this policy, we will post a notice visible upon your first usage of the Services after the update becomes effective, and may also send an email if we believe the circumstances of update warrant it.
As used in this Policy:
- “Personal Information” means 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.
- “Usage Information” means 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.
- “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.
- “Cookie(s)” means a small piece of software that may be placed on a Visitor’s machine during the use of our Site.
- “You” refers to Guidebook Customers, Visitors, or End Users as identified in the applicable section below, or, if not specified by section, to all of these.
- “Content” means information other than Personal Information that any End User, Visitor, or Guidebook Customer uploads, links or posts through a Guide and/or the Site.
INFORMATION WE COLLECT THROUGH THE SERVICES
- 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.
HOW WE USE YOUR INFORMATION
- We use your Personal Information to provide and improve the Services, complete your transactions, administer your inquiries, and contact you regarding account activities, new version and product offerings, or other communications relevant to the Services.
- We use a third party payment processor, Stripe (or a similar service we may engage in the future), to process any payment transactions. 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. Guidebook does not view, store, or transmit your Payment Information.
- 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 user 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.
- 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 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).
- Guidebook uses third party analytics tools to review and analyze your behavior using a Guide, the Guidebook App, and/or the Site to help us operate, maintain improve our products and services.
- 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.
- 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.
- Guidebook uses third party analytics tools to review and analyze your behavior using a Guide, the Guidebook App, and/or the Site to help us operate, maintain and improve our products and services.
- 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.
- We use Usage Information so that we can improve the Site, optimize its performance, and learn which parts are most popular to Visitors.
HOW WE SHARE YOUR INFORMATION
In addition to the sharing through usages described above, we may share your Personal Information:
With our 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 generally 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.
In the course of material business transactions:
To comply with applicable law or protect others:
- 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.
With your informed consent.
HOW WE STORE AND SECURE 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.
HOW TO ACCESS AND UPDATE YOUR INFORMATION
If you have any questions about our privacy practices with respect to your Personal Information you can always email us at email@example.com. If you wish to remove the information we have about you, please send an email requesting such deletion to firstname.lastname@example.org and we will as soon as practicable, remove your information from our systems, provided some backup copies may remain for a short period of time thereafter before their removal. This will also delete information about the guides you had previously downloaded along with your account, other than meta data that lets us know that the guide was downloaded by a non-specific user.
You can update your Profile or Social Information within the Guidebook App by visiting the “Settings” menu (reflected by a gear icon in the top left hand corner of the Guidebook App).
THIRD PARTY SITES
Our Site contains, and the Guidebook App or a Guide may contain, links to websites owned or controlled by a third party. If you choose to visit one of these websites, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other websites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit
OUR POLICIES CONCERNING CHILDREN
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 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 any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.
Your 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.
YOUR DISPUTES WITH GUIDEBOOK AND OUR COMMITMENT TO THE PRIVACY SHIELD PRINCIPLES
You have the right to opt-out of any use or sharing of your information – please email us at firstname.lastname@example.org to do so if it is not clear how to opt-out elsewhere in this policy. Please note, however, that we cannot control the use of your information that was already or separately in the possession of a Guidebook Customer.
In the unfortunate event we find ourselves in a dispute with you, we offer members of our support team to first help you resolve the issue free of charge. In the unfortunate event that we are not able to resolve such a dispute, the following dispute resolution procedures will apply:
About Privacy Shield
EU and Swiss residents have the right to access personal data about them and to request the correction, amendment, removal and/or limitation of the use and disclosure of their personal data processed by Guidebook. Such requests should be sent by email to email@example.com or by regular mail to:
Attn: Security Department
1 Zoe Street
San Francisco, CA 94107
Dispute Resolution and Arbitration.
If you reside within the EU or Switzerland, any inquiries or complaints regarding Guidebook’s compliance with the Privacy Shield or U.S.-Swiss Safe Harbor programs should be sent to the Guidebook email and postal addresses set forth above. Guidebook will respond within 45 days.
If you do not receive timely acknowledgment of your complaint, or if you cannot resolve your complaint directly with Guidebook, you can contact the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), by visiting its web site at http://info.adr.org/safeharbor. Guidebook has engaged the ICDR/AAA as an independent dispute resolution provider to address unresolved Privacy Shield complaints.
You may also refer a complaint to your local data protection authority and we will work with them to resolve your concern.
Under certain conditions, individuals may be able to invoke binding arbitration before the Privacy Shield Panel jointly created by the U.S. Department of Commerce and the European Commission to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles (link to https://www.privacyshield.gov/article?id=ANNEX-I-introduction).
Federal Trade Commission Enforcement.
Guidebook is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to its compliance with the EU-U.S. Privacy Shield Framework.
Disclosure Requests by Public Authorities.
Guidebook may be required to disclose your personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requests.
Onward Transfer Liability.
If a third party processes personal data on behalf of Guidebook in a manner inconsistent with the Privacy Shield Principles, Guidebook could be liable unless Guidebook can prove that it is not responsible for the event giving rise to any damage.
WHERE TO CONTACT US
Attn: Security Department
1 Zoe Street
San Francisco, CA 94107
Initial Posting: April 25, 2011
Effective Date: November 28, 2016
Last Updated Date: November 28, 2016
For a redline against the prior version, please e-mail us at firstname.lastname@example.org.