Privacy Policy
Last Updated: [DATE].
This Privacy Policy (“Policy”) explains the information
collection, use, and sharing practices of [COMPANY NAME] (“we,” “us,” and “our”).
Unless otherwise stated, this Policy describes and governs
the information collection, use, and sharing practices of [COMPANY NAME]
with respect to your use of our website ([WEBSITE URL]) and the services
(“Services”) we provide and/or host on our servers.
Before you use or submit any information through or in
connection with the Services, please carefully review this Privacy Policy. By
using any part of the Services, you understand that your information will be
collected, used, and disclosed as outlined in this Privacy Policy.
If you do not agree to this privacy policy, please do not
use our Services.
Our
Principles
[COMPANY NAME] has designed this policy to be
consistent with the following principles:
- Privacy policies should be human readable and easy to find.
- Data collection, storage, and processing should be
simplified as much as possible to enhance security, ensure consistency,
and make the practices easy for users to understand.
- Data practices should meet the reasonable expectations
of users.
Information
We Collect
We collect information in multiple ways, including when you
provide information directly to us; when we passively collect information from
you, such as from your browser or device; and from third parties.
Information
You Provide Directly to Us
We will collect any information you provide to us. We may
collect information from you in a variety of ways, such as when you: (a) create
an online account, (b) make a donation or purchase, (c) contact us or provide
feedback, (d) subscribe to our newsletter, or (e) subscribe to our newsletter.
This information may include but is not limited to your name, email address,
phone number, mailing address, payment information and your geographic
location.
Information
that Is Automatically Collected
Device/Usage Information
We may automatically collect certain information about the
computer or devices (including mobile devices or tablets) you use to access the
Services. As described further below, we may collect and analyze (a) device
information such as IP addresses, location information (by country and city),
unique device identifiers, IMEI and TCP/IP address, browser types, browser
language, operating system, mobile device carrier information, and (b)
information related to the ways in which you interact with the Services, such
as referring and exit web pages and URLs, platform type, the number of clicks,
domain names, landing pages, pages and content viewed and the order of those
pages, statistical information about the use of the Services, the amount of
time spent on particular pages, the date and time you used the Services, the
frequency of your use of the Services, error logs, and other similar
information. As described further below, we may use third-party analytics
providers and technologies, including cookies and similar tools, to assist in
collecting this information.
Cookies and Other Tracking Technologies
We also collect data about your use of the Services through
the use of Internet server logs and online tracking technologies, like cookies
and/or tracking pixels. A web server log is a file where website activity is
stored. A cookie is a small text file that is placed on your computer when you
visit a website, that enables us to: (a) recognize your computer; (b) store
your preferences and settings; (c) understand the web pages of the Services you
have visited and the referral sites that have led you to our Services; (d)
enhance your user experience by delivering content specific to your
inferred interests; (e) perform searches and analytics; and (f) assist with
security administrative functions. Tracking pixels (sometimes referred to as
web beacons or clear GIFs) are tiny electronic tags with a unique identifier
embedded in websites, online ads and/or email, and that are designed to provide
usage information like ad impressions or clicks, measure popularity of the
Services and associated advertising, and to access user cookies. We may also
use tracking technologies in our license buttons and/or icons that you can
embed on other sites/services to track the website addresses where they are
embedded, gauge user interaction with them, and determine the number of unique
viewers of them. If you receive email from us (such as the CC newsletter,
campaign updates, or other ongoing email communications from CC), we may use
certain analytics tools, such as clear GIFs, to capture data such as whether
you open our message, click on any links or banners our email contains, or
otherwise interact with what we send. This data allows us to gauge the
effectiveness of our communications and marketing campaigns. As we adopt
additional technologies, we may also gather additional information through
other methods.
Please note that you can change your settings to notify you
when a cookie is being set or updated, or to block cookies altogether. Please
consult the “Help” section of your browser for more information. Please note
that by blocking any or all cookies, you may not have access to certain
features or offerings of the Services.
For more information about how we use cookies, please read
our Cookie Policy.
Information
from Third Parties
the extent permitted by law, we may also collect
information from third parties, including public sources, social media
platforms, and marketing and market research firms. Depending on the source, this
information collected from third parties could include name, contact
information, demographic information, information about an individual’s
employer, information to verify identity or trustworthiness, and information
for other fraud or safety protection purposes.
How We
Use Your Information
We may use the information we collect from and about you
to:
- Fulfill the purposes for which you provided it.
- Provide and improve the Services, including to develop
new features or services, take steps to secure the Services, and for
technical and customer support.
- Fundraise, accept donations, or process transactions.
- Send you information about your interaction or
transactions with us, account alerts, or other communications, such as
newsletters to which you have subscribed.
- Process and respond to your inquiries or to request
your feedback.
- Conduct analytics, research, and reporting, including
to synthesize and derive insights from your use of our Services.
- Comply with the law and protect the safety, rights,
property, or security of [COMPANY NAME], the Services, our users, and the
general public; and
- Enforce our Terms of Use, including to investigate
potential violations thereof.
Please note that we may combine information that we collect
from you and about you (including automatically collected information) with
information we obtain about you from our affiliates and/or non-affiliated third
parties, and use such combined information in accordance with this Privacy
Policy.
We may aggregate and/or de-identify information collected
through the Services. We may use de-identified and/or aggregated data for any
purpose, including without limitation for research and marketing purposes.
When We
Disclose Your Information
We may disclose and/or share your information under the
following circumstances:
Service
Providers.
We may disclose your information with third parties who
perform services on our behalf, including without limitation, event management,
marketing, customer support, data storage, data analysis and processing, and
legal services.
Legal
Compliance and Protection of Creative Commons and Others.
We may disclose your information if required to do so by
law or on a good faith belief that such disclosure is permitted by this Privacy
Policy or reasonably necessary or appropriate for any of the following reasons:
(a) to comply with legal process; (b) to enforce or apply our Terms of Use and
this Privacy Policy, or other contracts with you, including investigation of
potential violations thereof; (c) enforce our Charter including the Code of
Conduct and policies contained and incorporated therein, (d) to respond to your
requests for customer service; and/or (e) to protect the rights, property, or
personal safety of [COMPANY NAME], our agents and affiliates, our users,
and the public. This includes exchanging information with other companies and
organizations for fraud protection, and spam/malware prevention, and similar
purposes.
Business
Transfers.
As we continue to develop our business, we may engage in
certain business transactions, such as the transfer or sale of our assets. In
such transactions, (including in contemplation of such transactions, e.g., due
diligence) your information may be disclosed. If any of our assets are sold or
transferred to a third party, customer information (including your email
address) would likely be one of the transferred business assets.
Affiliated
Companies.
We may disclose your information with current or future
affiliated companies.
Consent.
We may disclose your information to any third parties based
on your consent to do so.
Aggregate/De-identified
Information.
We may disclose de-identified and/or aggregated data for
any purpose to third parties, including advertisers, promotional partners,
and/or others.
Legal
Basis for Processing Personal Data
The laws in some jurisdictions require companies to tell
you about the legal ground they rely on to use or disclose information that can
be directly linked to or used to identify you. To the extent those laws apply,
our legal grounds for processing such information are as follows:
To Honor
Our Contractual Commitments to You.
Much of our processing of information is to meet our
contractual obligations to provide services to our users.
Legitimate
Interests.
In many cases, we handle information on the ground that it
furthers our legitimate interests in ways that are not overridden by the
interests or fundamental rights and freedoms of the affected individuals, these
include:
- Customer service
- Marketing, advertising, and fundraising
- Protecting our users, personnel, and property
- Managing user accounts
- Organizing and running events and programs
- Analyzing and improving our business
- Managing legal issues
We may also process information for the same legitimate
interests of our users and business partners.
Legal
Compliance.
We may need to use and disclose information in certain ways
to comply with our legal obligations.
Consent.
Where required by law, and in some other cases where
legally permissible, we handle information on the basis of consent. Where we
handle your information on the basis of consent, you have the right to withdraw
your consent; in accordance with applicable law.
Online
Analytics
We may use third-party web analytics services (such as
Google Analytics) on our Services to collect and analyze the information
discussed above, and to engage in auditing, research, or reporting. The
information (including your IP address) collected by various analytics
technologies described in the “Cookies and Other Tracking Technologies” section
above will be disclosed to or collected directly by these service providers,
who use the information to evaluate your use of the Services, including by
noting the third-party website from which you arrive to our Site, analyzing
usage trends, assisting with fraud prevention, and providing certain features
to you. To prevent Google Analytics from using your information for analytics,
you may install the official Google Analytics Opt-out Browser Add-on.
Your
Choices and Data Subject Rights
You have various rights with respect to the collection and
use of your information through the Services. Those choices are as
follows:
Email
Unsubscribe
You may unsubscribe from our marketing emails at any time
by clicking on the “unsubscribe” link at the bottom of each newsletter or by
emailing [EMAIL
ADDRESS] with your request.
Account
Preferences
If you have registered for an account with us through our
Services, you can update your account information or adjust your email
communications preferences by logging into your account and updating your
settings.
EU Data
Subject Rights
Individuals in the European Economic Area (“EEA”) and other
jurisdictions have certain legal rights (subject to applicable exceptions and
limitations) to obtain confirmation of whether we hold certain information
about them, to access such information, and to obtain its correction or
deletion in appropriate circumstances. You may have the right to object to our
handling of your information, restrict our processing of your information, and
to withdraw any consent you have provided. To exercise these rights, please
email us at [EMAIL
ADDRESS] with the nature of your request. You also have the right to go
directly to the relevant supervisory or legal authority, but we encourage you
to contact us so that we may resolve your concerns directly as best and as
promptly as we can.
International
Transfers
As described above in the “When We Disclose Your
Information” section, we may share your information with trusted service
providers or business partners in countries other than your country of
residence in accordance with applicable law. This means that some of your
information may be processed in countries that may not offer the same level of
protection as the privacy laws of your jurisdiction. By providing us with your
information, you acknowledge any such transfer, storage or use.
If we provide any information about you to any third
parties information processors located outside of the EEA, we will take
appropriate measures to ensure such companies protect your information
adequately in accordance with this Privacy Policy and other data protection
laws to govern the transfers of such data.
Security
Measures
We have implemented technical, physical, and organizational
security measures to protect against the loss, misuse, and/or alteration of
your information. These safeguards vary based on the sensitivity of the
information that we collect and store. However, we cannot and do not guarantee
that these measures will prevent every unauthorized attempt to access, use, or
disclose your information since despite our efforts, no Internet and/or other
electronic transmissions can be completely secure.
Children
The Services are intended for users over the age of 18 and
are not directed at children under the age of 13. If we become aware that we
have collected personal information (as defined by the Children’s Online
Privacy Protection Act) from children under the age of 13, or personal data (as
defined by the EU GDPR) from children under the age of 16, we will take
reasonable steps to delete it as soon as practicable.
Data
Retention
We retain the information we collect for as long as
necessary to fulfill the purposes set forth in this Privacy Policy or as long
as we are legally required or permitted to do so. Information may persist in
copies made for backup and business continuity purposes for additional time.
Third-Party
Links and Services
The Services may contain links to third-party websites
(e.g., social media sites like Facebook and Twitter), third-party plug-ins
(e.g., the Facebook “like” button and Twitter “follow” button), and other
services. If you choose to use these sites or features, you may disclose your
information not just to those third-parties, but also to their users and the
public more generally depending on how their services function. Creative
Commons is not responsible for the content or privacy practices of such third
party websites or services. The collection, use and disclosure of your
information will be subject to the privacy policies of the third party websites
or services, and not this Privacy Policy. We encourage you to read the privacy
statements of each and every site you visit.
Changes
to this Privacy Policy
We will continue to evaluate this Privacy Policy as we
update and expand our Services, and we may make changes to the Privacy Policy
accordingly. We will post any changes here and revise the date last updated
above. We encourage you to check this page periodically for updates to stay
informed on how we collect, use and share your information. If we make material
changes to this Privacy Policy, we will provide you with notice as required by
law.
Questions
About this Privacy Policy
If you have any questions about this Privacy Policy or our
privacy practices, you can contact us at: [EMAIL ADDRESS].