Privacy Policy
Privacy Policy
Effective: August 1, 2020
Our Privacy Policy explains how the National Alliance for Drug Endangered Children (National DEC) collects, uses, and discloses information about you. We use the terms “user,” “you,” and “your” to mean any person using our Platforms (web site, mobile application, learning management system) or attending related events, including any organization or person using our Platforms on an organization’s behalf. This Privacy Policy applies to the processing of information about users and other individuals that we collect when you use our Platforms or when you communicate with us. For information about choices you may have under this policy, please see “Your Choices” below. This Privacy Policy does not apply to the information that you may provide to third parties, such as users, and others with whom you may share information about yourself. For more information about the scope of our Privacy Policy, please see Section 4.5.
To make this Privacy Policy easier to understand, we have provided summaries below. Even though we have provided summaries, it is important for you to read the entire policy carefully. If you wish to access any particular section of this Privacy Policy, use the list below to jump to that section.
1. Collection of Information
2. Use of Information
3. Sharing of Information
4. Additional Details
5. Your Choices
6. Data Rights
7. Privacy Rights
8. Contact Us
1. Collection of Information
Summary: We collect information about you when you:
· Use the Platforms
· Attend an event
· Visit our website
· Communicate with us
We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies. If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.
1.1 Information You Provide to Us
We collect information that you provide directly to us. For example, we collect information that you provide if you choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include identifiers, such as your name, email address, postal address, and phone number; payment, if applicable, and commercial information, such as payment method data and purchases, if any; demographic information and any other personal information that you choose to provide, choices of interests, groups, and professional or employment-related information, including your role, company, and years of experience. Certain information about yourself is optional to provide. Your choice of groups is also optional, but we are required to process this information in order to indicate that you are a user of the groups that you join. See Section 2 to learn how we will use the information that you provide to personalize our recommendations and other content to you.
On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions, or your sexual identity. This, and other kinds of sensitive information, is given special protection in accordance with applicable law. Posting personal or sensitive information about others without their permission is against our Community Guidelines.
1.2 Information We Collect Automatically When You Use the Platforms
When you use our Platforms, we automatically collect internet and other electronic network activity information about you and other information, including:
· Log Information: We collect log information about your use of the Platforms, including the type of browser that you use; the time, duration, and frequency of your access; Platforms pages viewed; your IP address; and the page you visited before visiting our Platforms.
· Device Information: We collect information about the computer or mobile device that you use to access our Platforms, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
· Geolocation Information: We may collect information about the location of your device each time you use our Platforms based on your consent to the collection of this information, such as when you enable location services. For further information see Section 5.2. We may also collect information, such as your IP address, that can sometimes be used to approximate your location based on your device settings.
· Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies and pixel tags (which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored on your hard drive or in device memory that help us improve our Platforms and your experience, and track usage of our Platforms. Pixel tags are electronic images that may be used in our Platforms or emails, and track usage of our Platforms and effectiveness of communications. You can learn more about the types of cookies we and our service providers use by reading our Cookie Policy.
· Other Information: Based on your consent, we may collect other information from your device, such as photos from your camera roll or calendar information you want to manage via the Platforms.
1.3 Information We Collect From Other Sources
We may collect information about you from other sources, such as through certain features on the Platforms you elect to use. We rely on these third parties to either have your consent or ensure that they are otherwise legally permitted or required to disclose your information to us. Examples include:
· Social Media Services. We may have access to third-party account information if you use our Platforms feature to share a link.
· User Content. We may receive information about you when you or another user uploads posts, completes a form or responds to other content on the Platforms. For further details about the rights over this information available to individuals, see Section 6.
· Current or Future Organization Affiliates. We may receive information about you from our current or future parents, subsidiaries, or affiliates.
· Information From Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources, such as third-party publishers, advertising networks and other third parties as permitted by law.
· We may analyze and make inferences from the information we collect.
2. Use Of Information
Summary: We use information about you to:
· Operate, improve, promote, and protect our Platforms
· Communicate with you
· Personalize content
2.1 Operating our Platforms
We may use information about you described above for various business purposes related to operating our Platforms, including to:
· Provide, maintain, and improve our Platforms, including to process transactions, develop new products and services (for example, including you in tests or pilots of new or revised Platforms functions, such as messaging or search functionality or using information about your usage of the Platforms to develop new or revised messaging or search functionality), and manage the performance of our Platforms.
· Personalize the Platforms, for example, to suggest content in which we think you may be interested.
· Allow you to share information about your use of the Platforms through a third-party social media service and to provide you with better recommendations.
· Monitor and analyze trends, usage, and activities in connection with our Platforms.
· Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of National DEC and others; to enforce compliance with our policies; and to comply with applicable law and government requests; and
· Perform accounting and administrative tasks, and enforce or manage legal claims.
2.2 Communicating With You
We may use information about you for various business purposes related to communicating with you, including to:
· Respond to your comments, questions, and requests, and provide customer service.
· Communicate with you, in accordance with your settings, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about events on our Platforms that are being held near your location, and to otherwise communicate with you in accordance with Section 2.3.
· Notify you about communications of other users, in accordance with the communication preferences that you indicate.
· Send you technical notices, updates, security alerts and support, and administrative messages.
2.3 Advertising And Other Uses
We may use information about you for various other business purposes, including to:
· We do not use user information to sell advertising on our Platforms.
· Provide content, features, or sponsorships that match user profiles or interests
· Facilitate promotions.
· Send you marketing communications, subject to applicable law.
· Combine with information that we collect for the purposes described in this Privacy Policy.
· Carry out any other purposes described to you at the time that we collected the information.
2.4 Legal Basis for Processing
· If you are in a jurisdiction that requires a specific legal basis for processing personal data, our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
· We process information about you in order to provide our services in accordance with our Terms of Service, for example, to allow you to join groups or to display your profile to other users; to allow us to send you important service updates; and to perform a contract.
· We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platforms).
· Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Joining such groups or posting information on the Platforms about these topics is entirely voluntary and, depending on the settings of the group and your profile (e.g., public or private), our legal basis for processing any sensitive information is either that you manifestly make it public or your explicit consent.
· In some cases, we may also have a legal obligation to process information about you, or may otherwise need the information to protect your vital interests or those of another person. For example, we may process information, if we believe doing so is required by, or in accordance with, applicable law, regulation, legal process, or audits.
3. Sharing Of Information
Summary: We may disclose personal information about you, including:
· To users or social media services, depending on how you engage with the Platforms. Information that is public on our Platforms is accessible to others both on and off the Platforms.
· To our third-party service providers who help us to operate or improve our Platforms.
· To authorities to comply with legal obligations or requests and to protect and defend our rights and property.
· To an affiliate or successor entity or otherwise as part of a corporate transaction
· Among our businesses and affiliated organizations.
· When you direct us to share your information.
· We may also share information in a manner that does not identify you, such as de-identified or aggregated information. Such information is not subject to this Privacy Policy.
· We do not sell or share information about you except as described in this Privacy Policy.
3.1 Through Our Platforms
· We share some of the information that we collect by displaying it on our Platforms according to your user profile. Some information, such as username, is always public. Some information, such as interests, is public by default, but can be hidden on our Platforms. Some information, such as user groups, will always be visible to other users, and may be public, depending on the settings of that group. We recommend that you check the group settings and what information will be available before joining the group to ensure that you are happy with the information that is visible to others.
· Information that is public on our Platforms is visible to others on and off the Platforms.
3.2 Group Networks
· Our network administrators have access to the content on our Platforms, including information about group participants. Network administrators find it helpful to have access to the email addresses of users to easily communicate with and administer the Platforms. Therefore, we will provide ways for you to share your email address with our network administrator. See this article for more information about Network Administrators and their Users.
3.3 With Our Service Providers
· We may use service providers in connection with operating and improving the Platforms to assist with certain business purposes, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. These service providers, which include data analytics providers, may access, process, and store information about you on our behalf for the purposes we authorize, subject to confidentiality obligations.
3.4 Following The Law And Protecting Our Platforms
· We may access, preserve, and disclose information about you to government entities and other third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary, to protect the rights, property, or safety of, or prevent fraud or abuse of our Platforms.
3.5 Social Sharing And Other Tools
· Our Platforms may offer social sharing features and other integrated tools which let you share actions that you take on our Platforms with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. The third-party services' use of the information will be governed by the third parties’ privacy policies, and we do not control the third parties’ use of the shared data. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review the privacy policies of the services that provide these features.
3 .6 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers
· If National DEC is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.
3.7 Other Situations
· We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. Such information is not subject to this Privacy Policy.
· We may also share information about you with your consent or at your direction or where we are legally entitled to do so.
4. Additional Details
Summary: We may allow others to use technologies that collect information about you to provide analytic services. You may be able to disable the collection or use of this information. National DEC is based in and governed by U.S. law and we will be processing, transferring, and storing information in and to the U.S. and other countries. We have implemented technical and organizational measures to protect your personal information. We cannot guarantee these controls will provide absolute security. This Privacy Policy is periodically updated, and does not apply to third parties.
4.1 Analytics Services Provided by Others
· We and others may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platforms and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.
4.2 Transfer Of Information To The U.S. And Other Countries
· National DEC is based in the United States. Information about you will be transferred to, and processed in, the U.S. and countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguards, such as standard contractual clauses, to require that your information will remain protected in accordance with this Privacy Policy.
4.3 Security
· We employ technical and organizational measures designed to protect your information that is under our control and that we process on your behalf from unauthorized access, collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. For example, we store all information that you provide to us on servers on which security controls are used. We train employees regarding our data privacy policies and procedures, and authorize employees to access personal information as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.
· Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.
4.4 Data Retention
· We retain certain information that we collect from you while you visit or are a user of the Platforms for the following business purposes:
o So you can use our Platforms.
o To ensure that we do not communicate with you if you have asked us not to.
o To better understand the traffic to our Platforms so that we can provide all users with the best possible experience.
o To detect and prevent abuse of our Platforms, illegal activities and breaches of our Terms of Service.
o To comply with applicable legal requirements.
o When we have no ongoing legitimate business need to process your information, we will either delete it or take steps to de-identify or anonymize it in accordance with applicable law.
4.5 Policy Scope
· This Privacy Policy does not apply to information that you have provided or made accessible to third parties, such as other users, including network administrators, and others with whom you may share information about yourself. Our Platforms may direct you to a third-party service, such as social media services, or a portion of our Platforms may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platforms). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our Platforms or if we share information with these third parties.
· Users, including network administrators, are directly responsible for complying with all requirements of applicable privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts, organizing and communicating with groups, or administering networks.
4.6 Revisions To This Policy
· We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we make any material change to this policy, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Platforms.
5. Your Choices
Summary: You can remove photo tags if applicable and if you wish.
Consult your device settings for information about how to deactivate location-based features at any time.
You have the right to opt out of receiving National DEC’s promotional messages, but you may still receive other non-promotional communications.
5.1 Your Choices: Location Information
· When you first access the Platforms, depending on your device settings, we will collect information about your location, which we use to make better recommendations for resources in your area, and to improve our Platforms. If you do not want us to collect information about your location, then you can prevent this by taking the following steps:
o If using a mobile app, by changing the settings on your device.
o If using our website, your approximate location information will be obtained via a cookie. Please refer to our Cookie Policy for additional information on how to manage our use of cookies.
o Note that our Platforms or their features may no longer function properly if you change your settings.
o Your mobile device settings may also give you the option to choose whether to allow us to view your geolocation on a continuous basis, only when using the app, or never. Allowing us to view your geolocation when you are not using the app allows us to provide you with recommendations on a regular basis. Please refer to your device’s guide for additional information on how to adjust location services.
5.2 Your Choices: Cookies
· We may use and allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platforms and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.
5.3 Your Choices: Promotional Communications
· You can control some of the messages that you receive from National DEC and other users by selecting the unsubscribe link in the message that you receive. We will also send you a link to these settings when you first sign up and in subsequent messages. If you opt out, we may still send you non-promotional messages, such as those about our ongoing business relations. In addition, please consult the privacy policies of other users for information about how to control or opt out of promotional messages from them off the Platforms.
5.4 Your Choices: Photo Tagging
· You can tag photos of yourself and others. When a photo has been tagged it means that the name of that person will appear alongside the photo.
· We will notify you when another user has tagged you in a photo or when additional comments are added to such photos. You can remove tags by selecting the “untag” option next to your name. You can also report inappropriate content to National DEC. You are responsible for obtaining permission from non-users to post a photo of them on the Platforms.
6. Data Rights
Summary: You may have the right to exercise data protection rights, including to request that National DEC deletes, amends, or provides you access to your information.
You have the right to opt out of receiving National DEC’s promotional messages, but you may still receive other communications.
You can complain to your local data protection authority about the use of your information.
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us with your request by sending an email to info@nationaldec.org.
Rights that you may have, depending on the jurisdiction in which you live, may include:
· Accessing, correcting, updating, or requesting deletion of your information.
· Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
· Opting out from receiving communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you.
· Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
· Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here.
· Note that National DEC is a controller of your information. Network administrators may also act as controllers of your information. You should contact these users if you have any questions about how they use information that you have provided to them.
7. California Privacy Rights
During the preceding 12 months, National DEC has collected, used, and shared the categories of personal information described above in this Privacy Policy. California residents have certain rights to access and delete their personal information and to request transparency about our privacy practices. If you would like to access or delete your information, or otherwise exercise your rights under the CCPA, please see Section 6. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services for exercising your rights unless those differences are permitted by law. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
8. Contact Us
Summary: If you have any questions, you can contact us at info@nationaldec.org.
Under European data protection law, the controller of your information is National DEC a 501c3, nonprofit organization.
If you have any questions or complaints about this Privacy Policy or how we use your information, please contact info@nationaldec.org.
