This Privacy Policy (“Policy”) explains the information collection, use, and sharing practices of Creative Commons Corporation (“CC”, “we”, “us”, and “our”), in connection with its operation of the Open COVID Pledge website made available at https://opencovidpledge.org (the “Website”), as well as the services (the “Services”) provided through the Website. CC assumes no responsibility for the privacy practices related to information gathered through the Website prior to August 27, 2020, the date on which CC first assumed operation of the Website.

Before you use or submit any information through the Website or in connection with the Services, please carefully review this Privacy Policy. By using any part of the Website or 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 THE WEBSITE OR THE SERVICES.

1. 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 information we receive from third parties.

Information You Provide Directly to Us

We collect the information you provide to us. We may collect information from you in a variety of ways, such as when you: (a) submit a request to be listed on our Website as a pledgor or supporter of the Open COVID Pledge, (b) contact us or provide feedback, (c) share your Pledge and/or your logo, and/or (d) subscribe to any newsletter or other communication that we might provide. This information may include but is not limited to your name, email address, phone number, mailing address, photo, geographic location, and your social media handles.

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, 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 any 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 (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Information from Third Parties

We may also collect information about you or others through third parties. For example, if you request listing as a supporter, we may request and collect information from the individuals you identified.  To the extent permitted by law, we may also collect information from third parties, including public sources and social media platforms. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information to verify identity or trustworthiness, and information for other fraud or safety protection purposes.

2. How We Use Your Information

We may use the information we collect from and about you in order to, among other things:

• Fulfill the purposes for which you provided it;
• Provide and improve the Services, including to develop new features or services, promote Open COVID Pledge community collaboration, take steps to secure the Services, and for technical and customer support;
• Send you information about your relationship with us or other communications, such as any newsletters if any 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; and
• Comply with the law and protect the safety, rights, property, or security of CC, the Services, our users, and the general public.

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 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.

3. 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, data storage, data analysis and processing, and legal services.
• Legal Compliance and Protection of CC 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 agreements with you; (c) to respond to your requests for Services; and/or (d) to protect the rights, property, or personal safety of CC, 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 Services, we may engage in certain business transactions, such as the transfer of our assets such as the Website to similarly minded organizations. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of CC’s assets are sold or transferred to a third party, user information (including your email address) would likely be one of the transferred business assets.
• Affiliated Organizations. We may disclose your information with current or future affiliated organizations.
• 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.

4. 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 Any Contractual Commitments to You. Much of our processing of information is to meet any contractual obligations to provide services to our users we may have to you as a user of our Services.
• 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
  Organizing and running events and programs
• Analyzing and improving our Services
• Managing legal issues

We may also process information for the same legitimate interests of our users and 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.

5. 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 Google Analytics Opt-out Browser Add-on by clicking here.

6. 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 – If we establish a newsletter or similar communications or outreach, you may unsubscribe from those at any time by emailing ocpinfo@creativecommons.org with your request.
• Confirmation of whether we hold certain information about you, 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 ocpinfo@creativecommons.org 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.

7. International Transfers

Our computer systems are currently based in the United States. 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, including the United States, in accordance with applicable law. This means that some of your information may be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction. By providing us with your information, you acknowledge and consent to 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.

8.  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.

9.  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.

10.  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 such as patent search platforms and registries. 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. CC 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.

11.  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.

12.  Questions About this Privacy Policy

If you have any questions about this Privacy Policy or our privacy practices, you can contact us at: ocpinfo@creativecommons.org

Prior version: April 7, 2020 [link]