Privacy Policy

Last Updated: October 5, 2020

Chacruna Institute (“we” or “us” or “our”) take privacy seriously and are committed to protecting it through our compliance with this Privacy Policy.

We are committed to safeguarding your privacy and ensuring that your personal data is protected. This Privacy Policy describes (i) the types of information we may collect from you or that you may provide when you communicate with us (whether electronically, by telephone or in writing), visit our website (www.chacruna.net) (our “Website”), or that we obtain from third party sources, and (ii) our practices for processing and protecting that information.

This Privacy Policy applies to personal data processed by us in connection with the services we offer. This includes personal data collected by us directly and indirectly as described below. This Privacy Policy does not apply to any personal data collected from or about any of our employees.

This Privacy Policy also applies to our targeted content, including online advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”). These Third Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Sites.

1. WHO IS RESPONSIBLE FOR WHAT HAPPENS WITH YOUR DATA?

We are responsible for processing your personal data. For the purposes of this Privacy Policy and applicable data protection law, we are the controller of your personal data and may provide access to your personal data to third party entity(ies) which may provide or offer to you certain products or services. This notice applies to all such entities and the personal data processed by such entities. If you have any questions, you can contact us via one of the following:

• Email: [email protected]

2. WHEN DO WE ASK FOR YOUR CONSENT?

By using our Website, you acknowledge that we are processing your personal data in accordance with this Privacy Policy. If you do not wish that we process your personal data in this way, please do not use our Website or otherwise provide our Website with your personal data.

We process your data for the purposes described in Section 4 below. In certain instances, we only process your data if you have consented, for example, where we process your personal data for use of cookies or process your sensitive personal data. Where we process your data on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your personal data for purposes not covered by this Privacy Policy.

3. WHAT HAPPENS IF OUR CUSTOMER IS A CHILD?

Our Website is not intended for children under 21 years of age. No one under age 21 may provide any information to or on the Website. We do not knowingly collect personal data from individuals under 21. If you are under 21, do not use or provide any information on this Website or on or through any of its features, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 21 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 21, please contact us at [email protected]_________.

4. FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Personal data means information that can directly or indirectly identify you or other individuals (“personal data”). This typically includes information such as your name, occupation, job title, employer name, home and work addresses, personal and work email addresses, mobile phone number, work telephone number and home telephone number, but can also include other information such as IP address, information about your family members or work colleagues, information about your preferences, records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements, and your product usage history and performance detail. Please see details in the following paragraphs.

We collect your personal data directly when you (i) provide us with personal data, (ii) request a catalog, quotation or information about our products and services, (iii) request or subscribe for information or mailings about our products and services, (iv) buy a product or service from us, or (v) contact our customer services. We may also receive personal data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.

In more detail, we process the following categories of personal data for the following purposes:

4.1 Conducting Business with You, Including Processing, Fulfilling, and Following Up on Online, Telephone and In-Person Purchases or Requests and Customer Services. For this purpose, we process the following personal data: your name, occupation, job title, employer name, home and work addresses, personal and work email addresses, mobile phone number, work telephone number, home telephone number, bank or payment card account information, Internet Protocol address, information about your family members or work colleagues, information about your preferences, records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements, and your product usage history and performance detail. We process your personal data when we conduct business,

including when you contact us, communicate with us whether electronically, by telephone or in writing) and/or we respond to your inquiries, questions and comments. We also process your personal data when you place an order or when you contact us about products and services. We further process personal data to provide you with our products or services that you request from us, including responding to your queries or comments and sending you products or samples that you have requested. We look at the products you have viewed on our Website. Our bases for this processing of your personal data are (i) the performance of the contract with you, or in order to take steps at your request prior to entering into a contract, (ii) our legitimate interests in the transmission of personal data within a group of undertakings for internal administrative purposes, including client data, and (iii) where applicable, your consent.

4.2 Suggestion of Our Products and Services; Marketing Communication. For this purposes, we process the following personal data: your name, occupation, job title, employer name, home and work addresses, personal and work email addresses, mobile phone number, work telephone number and home telephone number, IP address, information about your family members or work colleagues, records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements, and your product usage history and performance detail. The purposes of this processing is to provide information to customers or potential customers about our products and services. Our legitimate bases for processing this personal data are (i) our legitimate interests in pursuing direct marketing services to you and (ii) where applicable, your consent. You can opt out of receiving such communications directly from the communications we send you or by sending such request to us using one of the following:

• Email: [email protected]

4.3 Process Employment Applications. For this purpose, we process the following personal data: full name, alias, home address, email address, telephone number, Internet Protocol address, veteran status, voluntary self-identification of disability, and professional or employment-related information, including work experience, job titles, company names and dates of employment, education and education degree(s) and related information. Our purposes for processing this personal data is to facilitate applications for employment, conduct background checks, complete hiring, administer compensation and benefits, monitor employee performance and to otherwise manage employment relationship and interaction between employees. Our basis for processing this personal data are (i) our legitimate interests in the transmission of personal data for internal administrative purposes, including the hiring of personnel and for employee data purposes, and (ii) where applicable, your consent.

4.4 Surfing on our Website. For this purpose, we process the following personal data: information about the type of browser you use, details of the web pages you have viewed, Internet Protocol and device address, your Cookie ID, hyperlinks that you have clicked, your user name, gender, networks and any other information you choose to share when using Third Party Sites (such as when you use the “Like” functionality on Facebook), the websites you visited before arriving at our Website and information collected by cookies or similar tracking devices. We (and third party

service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our Website. Cookies are files that store information on your computer hard drive or browser that mean that we can recognize that you have visited us before. We use cookies and similar technologies (like pixels, fingerprints and other tools) to (i) improve our products and your experience on our Website by evaluating the use of our Website, products and services, and understand your browsing and shopping habits, (ii) analyze the effectiveness of our advertisements, (iii) personalize your website experience as well as evaluating statistics on website activity, (iv) evaluate (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you have visited it before, and what site referred you to it, (v) review the products that you have searched online and ended up purchasing in the store, (vi) make our Website easier to use, (vii) better tailor our Website and our products to your interests and needs, (viii) identify that you have visited our Website but did not purchase a product or service, (ix) collect information about your device and link to your personal data so as to ensure that our Website present the best web experience for you, and (x) supplementing the personal data that you provide to us with other information that we hold or that we may receive from commercially available sources, such as public databases and data aggregators, and third parties. Our bases for this processing of your personal data are (i) your consent and (ii) our legitimate interests in the transmission of personal data within a group of undertakings for internal administrative purposes and processing for the purposes of ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems.

It is always possible for you to visit our Website without disclosing your personal data. This requires that you have disabled cookies on your browser. You can opt out of the processing of such information by sending us a request to the contact information provided at the end of this Privacy Policy. Please note, however, that without cookies you may not be able to use all of the features of our Website.

4.5 Information, System, Network and Cyber Security. For this purpose, we process the following personal data: internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, products or advertisements, and product usage history and performance detail. Our purposes for processing this personal data is to monitor, detect and protect our organization, its systems, network, infrastructure, computers, information, intellectual property and other rights from unwanted security intrusion, unauthorized access, disclosure and acquisition of information, data and system breaches, hacking, industrial espionage, and cyberattacks. Our basis for processing this personal data is our legitimate interests in preventing unauthorized access, intrusion, misuse of company systems, networks, computers and information, including prevention of personal data breaches and cyber-attacks, piracy and malware prevention, intellectual property rights protection, intellectual property theft prevention, and website security.

4.6 General Corporate Operations and Due Diligence. For this purpose, we process the following personal data: your name, occupation, job title, employer name, home and work addresses, personal and work email addresses, mobile phone number, work telephone number, home telephone number, bank or payment card account information, Internet Protocol address, shopping habits, information about your family members or work colleagues, information about

your preferences, records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies, internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements, and your product usage history and performance detail. Our purposes for this processing are to develop or operate financial/credit/conduct and risk models, conduct internal analysis of customers, plan strategy and growth, collate reporting and management information to support business reporting, sharing information with other members of the corporate group, conduct back-office operations, monitoring physical access in our offices and any restricted or other areas, producing aggregate analytics, business intelligence, managing third party relationships (vendors, suppliers, media, and business partners), and processing identifiable data for the purpose of anonymizing/de- identifying/re-identifying it for the purposes of using the anonymized data for other purposes (product improvement, strategic partnerships, analytics, etc.). Our basis for processing this personal data is our legitimate interests in the day-to-day operation of our business and planning for strategic growth, including management of customer, client, vendor and other relationships, sharing intelligence with internal stakeholders, implementing safety procedures, and planning and allocating resources and budgeting.

5. HOW LONG DO WE STORE YOUR PERSONAL DATA?

Unless we are required by the law to store it for a different period, we will keep your personal data for the minimum amount of time that is required to fulfill the purposes for which we processed such information, including for the purposes of satisfying any legal, accounting, reporting or retention policies and requirements, including as necessary for us to defend against legal claim (which is generally seven years from the date of the last processing). Once your personal data is no longer required, we will permanently delete it in accordance with applicable law and our internal policies. We may retain your personal data in de-identified, aggregate form for so long as permitted by applicable law.

6. WHO IS RECEIVING YOUR PERSONAL DATA?

We engage other persons and entities (“Agents”) to perform certain services on our behalf. Pursuant to agreements with these Agents, which agreements afford appropriate, and all required, protections of your personal data, we may use these Agents to provide any or all of the following services on our behalf:

  • provide email, cyber security and other information technology services;
  • human resources, payroll, and employee recruitment services;
  • insurance services;
  • marketing and advertising services;
  • product delivery services;
  • product and services sales services;
  • accounting services; and
  • legal representation, including with regard to prevention harm to our entities, our products or services or a person or property (e.g., fraud prevention).

All of our Agents are bound by contract to refrain from using your personal data for any purpose other than providing the applicable service to us. We are liable to you for our Agents appropriate processing of your personal data in a manner consistent with this Privacy Policy and applicable data privacy laws and regulations.

As described above, we use Agents to manage our marketing and advertising on other websites. These Agents may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests. Any personal data gathered by these Agents is not provided by the Agents to us. It is only used by the applicable Agent pursuant to its own privacy policies. If you wish to opt out of interest-based advertising, please visit http://preferences- mgr.truste.com/ or http://optout.aboutads.info to manage your preferences. Alternatively, if you are located in the European Union, you may visit http://www.youronlinechoices.eu/. Please note that you may continue to receive generic ads.

In addition to disclosures described above, we may disclose or transfer personal data in connection with, or during negotiations of, any merger, acquisition, spin-off, sale of company assets, product lines or divisions, any financing or any similar transaction. We may also disclose personal data to third parties, such as law enforcement, to prevent damage or harm to us, our services or any person or property, if we believe that disclosure is required to meet national security or law enforcement requirements, or in response to a lawful request by a public authority. Except as described in this Privacy Policy, we will not otherwise disclose personal data to any third parties unless you have been provided with an opportunity to opt in to such disclosure.

We do not sell or share the personal data we process. If you would like more information about our disclosure of your personal data to third parties, please contact us at [email protected]

7. WHERE DO WE TRANSFER YOUR PERSONAL DATA?

We are based in the United States, and, therefore, we may transfer your personal data outside the place from which such data was collected. The countries to which we may transfer your personal data include countries that do not provide the same level of data protection as the country in which you reside and those that are not recognized by your country or the European Commission as providing an adequate level of data protection. We only transfer personal data to these countries subject to safeguards that assure the protection of your personal information, such as European Commission approved standard contractual clauses, or under circumstances where we are lawfully allowed to transfer such personal data, including, without limitation, the derogations for specific situations described in Article 49 of the European Union (“EU”) General Data Protection Regulation. These include (in summary) if the transfer is necessary to perform, or to form, a contract to which we are a party; the transfer is necessary for the establishment, exercise or defense of legal claims; you have provided your explicit consent to the transfer; or the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

8. WHAT ARE YOUR RIGHTS?

In accordance with applicable law, we will facilitate your right to obtain from us:

  • Confirmation as to whether or not we process personal data from you and, where that is the case, access to the personal data,
  • Rectification of inaccurate personal data,
  • Erasure of personal data,
  • Restriction of processing of personal data, and
  • Receive the personal data which you have provided to us and transmit those data to another data controller without hindrance.
    You may exercise any of these rights by contacting us at one of the following:

• Email: [email protected]

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal data. In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as information necessary to ensure proper authentication or to verify our Agents to which the information was provided.

9. CAN YOU WITHDRAW YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA?

In accordance with applicable law, we will facilitate your right to withdraw your consent to some of all of our processing of your personal data. You may exercise this right by contacting us at one of the following:

• Email: [email protected]

We will respond to your requests in accordance with, and within the appropriate timeframe determined by, the applicable law and/or regulation governing the use of the given personal data. In most cases, we will respond to requests within one month; provided, however, if the request is complex, we may extend its response time in accordance with applicable law and regulation. Please note that we may require additional information from you in order to honor the request, such as information necessary to ensure proper authentication or to verify our Agents to which the information was provided.

As set out above, you are entitled to withdraw your consent to the processing of your personal data but please note that if you do withdraw your consent, we may not be able to carry out our contractual obligations to you or further communicate with you.

10. CAN YOU COMPLAIN WITH THE APPLICABLE LEGAL AUTHORITIES?

You also have the right to lodge complaints with the applicable legal authorities, including, without limitation, the applicable EU supervisory authority(ies) (if you are an EU citizen).

11. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain appropriate technical and organizational measures to protect the personal data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data.

Our Website may contain links to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our Website, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy policies for the websites you visit.

12. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.100 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at one of the following:

• Email: [email protected]

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. At this time, our website does not support DNT codes.



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