Privacy Statement
The Special Representative of the Secretary-General for Business and Human Rights, and its service providers, including T0Media Consulting and Productions ("SRSG", "we", "us"), are concerned about privacy issues and want you to be familiar with how we collect, use and disclose Personally Identifiable Information (as defined below). This Privacy Statement (the "Statement") describes our practices in connection with Personally Identifiable Information that we collect through the Internet site currently located at http://www.srsgconsultation.org/ (together with any successor site(s), the "Site"). This Statement does not address the collection, use or disclosure of information by any of our affiliates (collectively, "Affiliated Entities").
By providing Personally Identifiable Information to SRSG, you agree to the terms and conditions of this Statement. If you do not agree to the terms and conditions of this Statement, please do not provide any Personally Identifiable Information to SRSG. We reserve the right to change this Statement without prior notice. You can determine when this Statement was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Statement will become effective upon our posting of the revised version of this Statement on the Site. Use of the Site following such changes constitutes your acceptance of the version of this Statement then in effect.
1. What Types of Information Does SRSG Collect From Me? SRSG gathers two basic types of information from you: "Personally Identifiable Information" (or "PII") and "Non-Personally Identifiable Information" (or "Non-PII"). Personally Identifiable Information is information that identifies you as an individual. Non-Personally Identifiable Information is aggregated information, demographic information and any other information that does not reveal your specific identity.
a. Personally Identifiable Information. You are not required to provide PII to access the Site. However, in order for you to take advantage of certain functionality available through the Site (for example, posting comments or receiving update notices), we may require that you furnish PII. We collect PII from you, such as your name, postal address, telephone number and e-mail address only when you voluntarily provide it to us, with the exception of IP address information, which is collected automatically. You may also make PII publicly available through information disclosed in public areas of the Site (such as comments posted to Forums). See paragraphs 4(a) and 4(b) for more information on this functionality.
b. Non-Personally Identifiable Information. We and our service providers may collect Non-PII, which is information that does not personally identify you, through the Site from sources such as environmental variables (such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version), “cookies” as well as so-called “pixel tags,” “web beacons,” “clear GIFs” and other similar technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. To learn more about cookies, please visit http://www.allaboutcookies.org/.
We also collect Non-PII (e.g., your geographic location) when you voluntarily provide this information to us. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code.
c. IP Addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time(s) of such visit(s) and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many web sites.
2. How Does SRSG Use Information Collected From Me?
a. Personally Identifiable Information. We may use PII about you in the following ways:
i. Fulfillment of Requests. SRSG may use PII about you to fulfill your requests, such as to send Site updates and event notices to you.
ii. Administrative Communications. From time to time, in our sole discretion, we may use PII about you to send you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.
iii. Internal Business Purposes. We may also use PII about you for our internal business purposes, such as data analysis, improving the Site, identifying usage trends, determining the effectiveness of our promotional campaigns and determining the fulfillment of the Site’s other purposes. IP address information may be used for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
b. Non-Personally Identifiable Information. Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-PII, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose.
In some instances, we may combine Non-PII with PII (such as embedding e-mail addresses in cookies). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined.
3. How Is Personally Identifiable Information Disclosed?
a. Third Party Service Providers. We work with third parties who provide services such as data analysis, infrastructure provision, IT services, e-mail delivery services and other similar services. We may share PII about you with third parties for the purpose of enabling these third parties to provide services. See paragraphs 4(a) and 4(b) for PII that you may disclose on the Site.
b. Assignment. In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of SRSG 's business or assets (including without limitation in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect from Site users to an Affiliated Entity or a third party. Further, in the event we transfer control or management of the Site to an Affiliated Entity or a third party (including without limitation a special purpose entity created specifically to oversee operation of the Site), we may transfer any and all information that we collect from Site users to such Affiliated Entity or third party.
c. Law enforcement; emergencies; compliance. We may disclose PII about you to others as we believe to be appropriate (a) under applicable law including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any Affiliated Entities; (f) to protect the rights, privacy, safety or property of SRSG, the Affiliated Entities, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.
4. Other Important Notices Regarding Our Privacy Practices.
a. Profiles. We may provide functionality on the Site that allows you to create a publicly accessible profile (your “Profile”) and post certain information and materials on your Profile. Please note that your Profile, including all PII available in your Profile, may be accessible to other users. We urge you to exercise discretion and caution when deciding to disclose PII about you, or any other information, in your Profile. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF ANY PII YOU DISCLOSE IN YOUR PROFILE.
b. Information Posted by Visitors. SRSG may make available through the Site services to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Site becomes public information, and may be available to visitors to the Site and to the general public. In addition, if you choose to post information and materials on certain services available through the Site, certain PII about you will be available for other Site users to view. We urge you to exercise discretion and caution when deciding to disclose PII about you, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PII YOU VOLUNTARILY DISCLOSE THROUGH THE SITE.
c. Third Party Sites. The Site may contain links to third party web sites. These linked sites (including without limitation the web sites of Affiliated Entities) are not under SRSG's control, and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by SRSG or any Affiliated Entities. If you provide any PII through any such third party web site, your transaction will occur on such third party's web site (not the Site), and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, THE AFFILIATED ENTITIES.
d. Security. We use reasonable organizational, technical and administrative measures to protect PII under our control. Security measures and tools, such as firewalls, are in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with Section 4(j) ("Contacting Us") below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
e. Opt-Out. If you no longer wish to receive Site-related e-mails from us on a going-forward basis, or if you would prefer that we do not share PII about you on a going-forward basis with third parties, you may opt-out of receiving such e-mails or from such sharing by sending an e-mail to admin@srsgconsultation.org.
We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove PII about you from the databases of third parties with which we have already shared PII about you (i.e., to which we have already provided PII about you as of the date that we implement your opt-out request), or PII that has been acquired by third parties from information you have publicly disclosed by posting to the Site or making it accessible through your profile. If you wish to cease receiving e-mails from such third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or e-mails.
f. Changing or Suppressing PII. If you would like to review, correct, update, suppress or otherwise limit our use of the PII about you that has been previously provided to us, you may contact us by sending an e-mail to admin@srsgconsultation.org. For your protection, we will only implement such requests with respect to the PII associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request. In each event, you must clearly indicate the information that you wish to have changed, clearly indicate that you wish to have your PII suppressed from our database or clearly indicate the limitations you wish to put on our use of your PII. We will endeavor to comply with your request as soon as reasonably practicable. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed from those databases and/or other records. Finally, we are not responsible for removing, suppressing, or limiting the use of information from the databases of third parties with whom we have already shared your PII, or who have obtained your PII from information you have publicly disclosed by posting on the Site or making it accessible through your profile.
g. Note Regarding the Use of the Site by Children: The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through the Site. Individuals under the age of majority in the jurisdiction from which they are accessing the Site may not provide PII without first obtaining the permission of their legal guardian to do so.
h. Jurisdictional Issues. SRSG does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. The work of the SRSG is not limited to any single jurisdiction. By using the Site and submitting any PII, you consent to the transfer of PII to a country that you may not reside in, including Canada and the United States, which may provide a different level of data security than in your country of residence.
i. Contacting Us. If you have any questions regarding this Statement or our privacy practices, please contact us by e-mail at admin@srsgconsultation.org, or please write to the following address:
T0Media Consulting & Productions
c/o Daniel Teoh
155 Kent Street
London, Ontario
CANADA
N6A 5N7
Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit card information in your e-mail correspondence with us.