Last Update: April 7, 2022
Effective Date: April 7, 2022
Privacy and data protection are important to the Positive News Foundation (“PNF”, “we”, “us”, and “our(s)” in Dutch: Stichting Positive News) community. Transparency is, too. We’ve done our best to cut through the legal jargon and explain in simple terms what information we collect about you, what we use it for, and the situations in which we share it with others. Please read this privacy policy carefully. It applies to all interactions you have with the PNF’s products and services where this privacy policy appears or is referenced, including offline, as well as on websites and apps. This privacy policy does not apply to personal information the PNF collects from its employees, volunteers, and contractors. By accessing or using the PNF’s websites, apps, or services from which this privacy policy is referenced, you confirm that you have read, understand, and acknowledge the terms of this privacy policy. This privacy policy is not a contract and does not create any legal rights or obligations.
The collected information
When you use one of the PNF’s products or services, we (or our service providers or other vendors we engage to perform services on our behalf) collect, receive, or develop the following categories of information from or about you:
We collect Identifiers, Contact and Account Information. When you sign up for a newsletter, sign up as volunteer, purchase products and donate, you give us your full name and email address. If you want, you can give us a pseudonym instead of your legal name.
We collect Demographic Information. We may collect information like your gender. We collected Payment Information. We may collect your credit card and other payment information if you purchase products.
We collect Information You Submit. If you submit information, we will collect the information you provide to us. We also collect information when you submit a question or comment or apply for a (volunteer) job, or if you provide information when entering a contest or promotion.
We collect Device, Internet and Network Activity Information. So that we can make your experience better, we collect information about how you interact with our websites and apps, and third-party sites. This includes what areas of the websites you visit, for how long, and what content you view, and interact with. If you use our website(s) or applications, we may collect information about the browser or device you are using, operating system, device identifiers, and your IP address. We also receive some other information automatically when you use the PNF. We might track the pages you visit. We might look at what site you came from, or what site you visit when you leave us. If you use our mobile apps, we may also look at how often you use the app and where you downloaded it. When you use our websites or apps we may also collect operating system-provided device IDs or user-specific advertising IDs for advertisement tracking. We collect this information using the tracking tools described below.
We collect Location Information. To help you connect with other PNF users and to personalize your experience, we may ask for additional information, including your location. We also collect information about your general location, using your IP address. To learn more about how to control the collection of location information see the “Your Choices” section below.
We collect Employment-Related Information. When you apply for a job, or volunteer job, we collect the information you submit as part of your application and resume. This might include your work experience and previous employment, your education, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa or require sponsorship, and/or salary expectations. We may also conduct a credit check, background check, and employment verification to the extent permitted by applicable law.
We collect and develop Inferences. Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
How information is collected
We collect personal information about you from various sources, directly and indirectly, including from the following sources:
We collect information directly from you. We may request and collect Identifiers, Contact and Account Information, and Payment Information directly from you, such as when you contact us, donate to us, or when you purchase products from us. We also collect Information You Submit if you post a comment, make a request, or complete a survey. We collect Employment-Related Information if you apply for a job, also volunteer jobs.
We collect information passively from your devices. We use various tracking technologies such as web beacons, cookies, and embedded scripts to automatically collect information about you when you interact with our websites, apps, ads, and emails. We collect information about you over time and across devices this way.
We get information from third parties. If you connect through a third-party service, we collect information through that service. For example, if you connect your YouTube account with the PNF, you agree to be bound by the YouTube Terms of Service and also the Google Privacy Policy. We may also receive Employment-Related Information from a job network or social network if you choose to import your information from those platforms when applying for a job with us.
We receive information from our vendors. For instance, we may engage with vendors and service providers to collect or provide us with information about you, such as access to location services via wireless networks or cell towers near your mobile device, or your IP address. Our employment and recruiting vendors also give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information.
We combine information. We may combine information we have collected offline with information we collect online. We may combine information we get from a third party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.
How information is used
We use information to provide you with services and administer our websites and apps. For example, we use Payment Information to process payment for your purchase(s). We might also use your information to send push notifications on our app and websites to notify you about the content you might be interested in or activity updates. We use the information to analyze and improve our products and services. For example, we may use your information to make our websites, apps, services, and products better. We might use your information to better understand how you use our service, customize your experience with us (including the content, marketing materials, and advertisements you see), and conduct research and analysis.
We use information to comply with our obligations, to administer our websites and services, and for internal operations. For example, we use personal information to administer the websites, such as troubleshooting, data analysis, and testing. We use the information for marketing purposes. For example, we might use personal information to provide you with information about our services. We might tell you about new features or services. You may opt-in to receive our email newsletters.
We use the information for security, safety, and due diligence purposes. For example, we may use personal information to protect our company, customers, business partners, and their respective personnel. We may also use personal information to protect our websites or our services, prevent abuse, as well as to detect and investigate activities that may be illegal or prohibited (such as cyberattacks or fraudulent transactions). We may also use the information to conduct background, employment, and credit checks and to assess financial, reputational, credit, and other risks arising from any relationship or prospective relationship with you.
We use the information for hiring purposes. For example, we use Contact Information and Employment-Related Information to review your job applications and contact you about employment opportunities.
We use the information for verification purposes. For example, we will use certain pieces of personal information to verify your identity if you make requests pursuant to this privacy policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
We use the information to respond to your requests or questions. We use the information to contact you in response to your feedback or other matters related to our relationship with you (such as this privacy policy or our Terms of Use).
We use information as otherwise required or permitted by law, or as we may notify you at the time of collection.
We may use personal information to create de-identified or aggregated data that does not identify you or any other individual, or from which your identity cannot reasonably be ascertained. We may use and disclose de-identified, anonymous, or aggregated data as we choose.
How personal information is disclosed
We share your personal information only under these circumstances:
We share information with our marketing partners. PNF may work with advertising partners to serve you third-party advertisements, including interest-based advertisements, on PNF and on other services. Personal information received by our marketing partners and other parties may also be subject to their privacy policies. To learn about how to control how we share your information with marketing partners see the Your Choices section below.
We may share your personal information if we have to in order to comply with the law, to protect ourselves, our customers and others, and for safety and security purposes. We may share your information if we believe it’s reasonably necessary to comply with a law, regulation or legal process, including to respond to a court order or subpoena. We may also share this personal information if a government agency or investigatory body requests it. Nothing in this privacy policy is intended to limit any legal objections or defenses you might have to prevent efforts by third parties to compel disclosure of your information, including legal orders from the government. We might share your personal information in order to enforce our agreements and to protect our rights and/or the rights of others. We might share your personal information when we are investigating potential fraud, including any promotions fraud.
We share personal information with vendors and service providers that help us offer and improve our service. We may share information with vendors that provide PNF with certain technical tools and services (such as email and analytics services) that help us understand how people use PNF so we can make it better. We also share Payment Information with our service provider to process your payments.
We may share personal information if we sell, transfer or otherwise share some or all of our assets in connection with a merger, acquisition, reorganization, or sale of assets in the event of a bankruptcy. For example, if PNF sells any of its businesses or assets, applies for loans, or opens bank accounts, we may disclose your personal information to the prospective buyer, lender, or bank, as the case may be, as part of certain due diligence processes. We also share information for the purpose of management and administration of our business. If part of our business (including any of our affiliates, divisions, and business units) is acquired by a third party, we may include personal information as part of that transaction, which may include some or all categories of your personal information. We may also share your personal information if there is a change to our corporate structure. We may also share your information with others as they conduct diligence on our corporate changes. With your consent, after letting you know what information will be shared, and with whom.
We may disclose anonymous, aggregate information about how our users use the PNF websites and applications in a manner that doesn’t identify you individually. We may share non-personally identifiable, non- aggregate information (for example, anonymized Advertising IDs) with companies that help us improve our products and services, including advertising (such as research companies and analytics providers).
We may share personal information for other reasons we may describe to you from time to time or as permitted or required by law.
Options
You can always opt-out of receiving our newsletter emails. To stop receiving our emails, you can follow the instructions in any message you get from us. Even if you opt-out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.
You can control certain cookies and tracking tools. Cookies and HTML5 local storage are ways to keep information about your use of Internet services on your own mobile device or computer. We use cookies and HTML5 local storage to help us create your session, know when you’re logged in, and help us remember certain information about how you interact with the PNF. You can find more information about these tools in our Cookie Statement. If you’d rather not use cookies or HTML5 local storage, most browsers give you the option to turn them off, or require your approval before using them to keep information. If you choose not to keep information in cookies or HTML5 local storage, though, portions of the PNF websites and applications may not work as intended. Your browser may also give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. Please note that this privacy policy explains the PNF’s policies only, and doesn’t cover the practices of other services.
The PNF also uses web beacons in advertisements to allow the PNF and its advertising partners to see how users view and engage with advertisements. Depending on your advertising preferences set in your operating system, PNF may share your Advertising ID with advertising partners in a de-identified fashion that is not tied to your name or email address. We and third-party advertising networks, social media companies, and other services may collect information about your use of our websites and apps over time using cookies, beacons or other tracking technology so that they or we may display interest-based advertising using information gathered about you over time across multiple websites or other platforms. You can learn more about interested-based advertising, including how to opt-out of third-party partners’ advertising you see on PNF and on other services, by visiting http://www.aboutads.info/choices/ and https://optout.privacyrights.info/ and http://www.aboutads.info/appchoices. We also use and share certain hashed information to enable targeted advertising through marketing partners that use common online identifiers for use in online, in-app, and cross-channel advertising, you can opt-out of this network here.
Users in European countries can visit http://www.youronlinechoices.eu/ for more information on these topics. Alternatively, you can opt-out by discontinuing your use of the PNF’s websites and applications.
We use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.
Some browsers make it possible for you to signal that you don’t want your Internet browsing activity to be tracked. These features are not currently uniform, so we don’t respond to Do-Not-Track requests at this time. If you block cookies, certain features on our site may not work. If you block or reject cookies, not all of the tracking described here will stop.
Options you select and choices you make are browser, website and device-specific. If you clear your cookies or your browser’s cache, you will need to set your preferences again.
For European users
If you reside in the UK or a country in the European Economic Area (EEA), under European data protection law, data controllers are required to have a lawful basis for each use or disclosure of personal information. We rely on the following legal bases when we process your personal information:
- When necessary for our legitimate interest in providing services to our users. These legitimate interests include responding to your inquiries and requests for information, maintaining, improving, and analyzing our websites, mobile applications, ads, and the content and services we offer, detecting, preventing, or investigating security breaches or fraud, and facilitating the functionality of our websites and mobile applications. In specific situations, we require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact your rights, freedom, or interests. We will use legitimate interest after we have properly evaluated the data processing and conducted a necessary balancing test.
- When necessary for the performance of a contract. This includes processing your personal information in order to fulfill your request or provide the services that you have requested, including for example, when you have subscribed to the email service.
- When you provide your consent for us to use your information. In some cases, we may rely on your consent. If we process any information where your consent is our lawful basis, you will have the right to withdraw your consent at any time.
- To comply with our legal obligations. This is our legal basis for certain uses and disclosures of information required by applicable UK and EEA laws. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
If you are a resident of the UK or a country in the EEA, you also have certain rights and protections under the law regarding the collection, processing, and use of information about you. You have the right to:
- Confirm whether we have personal information about you.
- Access or request a copy of your personal information. We may verify your identity before providing you with any information. There is no cost to you in requesting to see your data, but please note that we reserve the right to charge you if you make subsequent requests.
- Request that we correct the personal information we have about you, in certain circumstances, and subject to some specific legal reasons where we may need to retain personal information as is.
- Request that we delete your personal information, subject to specific legal reasons where we may need to retain personal information. We may also deidentify or anonymize personal information in response to your request.
- Restrict or object to certain processing of your personal information where we do not have a legal basis to process your information.
These rights may be limited in some circumstances under applicable law. To exercise any of these privacy rights, please contact us at legal@positivenewsfoundation.org. Please know that in order for us to respond to your request we may require that you verify your identity. For security, privacy, or operational reasons, the PNF may only respond to valid requests when required by law or regulation.
We will retain your personal information for as long as necessary to provide the services you have requested while taking into account any legal requirements and tax and accounting rules.
If you need further assistance regarding your rights, please contact legal@positivenewsfoundation.org and we will consider your request in accordance with applicable laws.
California privacy rights
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.
If you reside in California, you can make the following more specific requests in addition with respect to your personal information:
- Access – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months. California residents can make this request online by emailing us at legal@positivenewsfoundation.org
- Deletion – You can request that we delete the personal information that we maintain about you, subject to certain exceptions. California residents can make this request online by emailing us at legal@positivenewsfoundation.org
- Do Not Sell My Info – You can request that we not sell your personal information by clicking here: https://forms.gle/UUzhVN9D8zSuhbuU8. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law. Please note that any opt-outs through these tools are specific to the device and browser you are using, so you should opt-out for each web browser and on each device you use. Your opt-out preferences will be deleted any time you clear your web browser’s cookie cache.
You may also opt-out of the sale in some instances by using the DAA CCPA Opt-Out Tool at https://optout.privacyrights.info/?c=1. In addition, you may be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. To opt-out of cookie-based tracking for advertising purposes, you will also need to separately visit https://optout.aboutads.info/ and https://optout.networkadvertising.org/.
PNF will not discriminate against you because you made any of these requests.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record-keeping purposes, and to process transactions and facilitate customer requests. Note that for purposes of these requests under this Privacy Policy, personal information does not include information about job applicants, volunteers, employees, and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.
We will take reasonable steps to verify your identity prior to responding to your requests. For example, we may utilize a third-party verification provider to assist with verifying your identity. The verification steps may vary depending on the sensitivity of the personal information.
California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent. If you are an authorized agent submitting a request on behalf of a California consumer please email legal@positivenewsfoundation.org.
PNF is not intended for users under the age of 18. We do not knowingly collect information from anyone under the age of 18.
For purposes of California residents making these requests, please also note the following regarding how we collect, use, and share your personal information as described in this Privacy Policy, including in the previous 12 months:
- We may collect, use, and disclose for our business and commercial purposes as described above, categories of personal information as set forth in applicable California law, including Identifiers, Contact Information, Payment Information, Demographic Information, Information You Submit, Device, Internet, and Network Activity Information, Location Information, Employment Related Information, and Inferences.
- We collect these categories of personal information from the sources described above, including directly from you, advertising partners and networks, data analytics providers, vendors and service providers, data brokers, social networks, third party publishers, our business and marketing partners, and other parties in connection with business transfers and for legal, safety, fraud prevention, and enforcement reasons.
- We may disclose each of the foregoing categories of personal information for the business and commercial purposes described in this privacy policy to the extent permitted by the applicable law to the categories of third parties as described in this privacy policy, which may include our service providers and suppliers; our business and marketing partners, including advertising networks, data analytics providers, data brokers, and social networks; and other parties in connection with business transfers and for legal, safety, fraud prevention, and enforcement reasons.
- We may “sell” categories of personal information, including Identifiers, Contact Information, Demographic Information, Information You Submit, Device, Internet, and Network Activity Information, Location Information, Employment Related Information, and Inferences. We may “sell” these categories of personal information to the categories of third parties described in this Privacy Policy, which may include our business and marketing partners, advertising networks, data analytics providers, data brokers, and social networks.
Data retention and security
The Internet is not 100% secure. We use standard security measures. We cannot promise that your use of our websites, apps, or services will be completely safe. Any transmission of your data to our websites is at your own risk. We encourage you to use caution when using the Internet. We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy, including, for example, for legal compliance, dispute resolution, contract enforcement, backup, archival, and other internal operations purposes. This includes data you or others provide to us and data generated from your use of our services. We also keep the information as otherwise required by law.
Data storage outside the EEA and international transfer
As an International organization based in The Netherlands, we store and use personal data inside and outside the EEA. The PNF services are offered globally so it is necessary to transfer your information internationally. In particular, your information will be transferred to and processed in the United States where our servers are located. The data protection and other laws of other countries, such as the United States, may not be as comprehensive as those in your country. By using our websites or mobile apps, or submitting your personal information, you consent to such transfer, storing, and processing. To ensure adequate protection of personal data in cross-border transfer and/or processing, we use appropriate safeguards as allowed under applicable law or regulation.
Links to 3rd party websites
We may link to third-party sites that we do not control. This Privacy Policy does not apply to the information practices of those websites. You should read the privacy policy of other websites carefully before disclosing any of your information. You access such linked websites at your own risk. We are not responsible for such third-party sites.
Children
The PNF’s websites and applications are not intended for children under the age of 18. We do not knowingly collect information from anyone under the age of 18. If you are a parent or legal guardian and think your minor under the age of 18 has given us information, you can contact us at legal@positivenewsfoundation.org. If you are under the age of 18, you may only use our websites or apps with the involvement of a parent or guardian.
Contact
We’d love to hear your questions, concerns, and feedback about this privacy policy. If you have suggestions for us, let us know at legal@positivenewsfoundation.org.
You may also write to us at:
Positive News Foundation
Attn. Legal Department
World Trade Center The Hague
Prinses Margrietplantsoen 33
2595 AM Den Haag
The Netherlands (Europe)
Severability of this Privacy Policy
The PNF and you agree and acknowledge that if any section, subsection, sentence, clause, or phrase contained in this Privacy Policy is found to be invalid, unenforceable, or otherwise inoperative, such decision shall not affect the validity of the remaining portion(s) of this Privacy Policy.
Changes to this Privacy Policy
As the PNF continues to develop, we may decide to revise this privacy policy from time to time. The most current version will govern our use of your information and will always be posted on the websites and apps to which this policy applies, and older versions are available upon request. If we make changes that we think will substantially alter your rights, we will notify you by posting a notice on our website. Your continued use of our websites, apps, or services means that you consent to any changes or revisions to the updated privacy policy.
