1. Anopenletterto.org Privacy Policy
  2. Data Protection Statement for European Union Users
  3. Consumer Privacy for California Users

1. AnOpenLetterTo.org
Privacy Policy

Effective Date: January 02, 2020

This policy explains what information we collect when you use anopenletterto.org’s sites, services, mobile applications, products, and content (“Services”). It also has information about how we store, use, transfer, and delete that information. Our aim is not just to comply with privacy law. It’s to earn your trust.

Information We Collect & How We Use It

The data tracking we do at Anopenletterto.org is to make our product work as well as possible. This includes basic product functions like personalizing what posts you see based on what we think you’ll like. So, to give you the best possible experience while using Anopenletterto.org, we collect information from your interactions with our Services. Some of this information, you actively tell us (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on actions you take while using Anopenletterto.org, such as what pages you view (including how much of a given page and for how long) and your use of product features. This information includes records of those interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information (how you got to a particular page).

We use this information to:

  • provide, test, improve, promote and personalize the Services
  • fight spam and other forms of abuse
  • generate aggregate, non-identifying information about how people use the Services

When you create your anopenletterto.org account, and authenticate with a third-party service (like Twitter, Facebook, Apple or Google) we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. We will never publish something through one of your third-party accounts without your express permission.

Information Disclosure

Anopenletterto.org won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you to a third-party.

We may transfer your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.

If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our services that we believe are improper.

Public Data

Search engines may index your anopenletterto.org user profile page, public interactions, and post pages, such that people may find these pages when searching against your name on services like Google, DuckDuckGo, or Bing. Users may also share links to your content on social media platforms such as Facebook or Twitter.

Data Storage

Anopenletterto.org uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run anopenletterto.org. We maintain two types of logs: server logs and event logs. By using the Services, you authorize anopenletterto.org to transfer, store, and use your information in the United States and any other country where we operate.

Third-Party Embeds

Some of the content that you see displayed on anopenletterto.org is not hosted by anopenletterto.org. These “embeds” are hosted by a third-party and embedded in a Anopenletterto.org page, so that it appears to be part of that page. For example: YouTube or Vimeo videos, Imgur or Giphy gifs, SoundCloud audio files, Twitter tweets, GitHub code snippets, or Scribd documents that appear within a anopenletterto.org post. These files send data to the hosted site just as if you were visiting that site directly (for example, when you load an anopenletterto.org post page with a YouTube video embedded in it, that video appears because of a pointer to files hosted by YouTube, and in turn YouTube receives data about your activity, such as your IP address and how much of the video you watch).

Anopenletterto.org doesn’t control what data third parties collect in cases like this, or what they ultimately do with it. So, third-party embeds on anopenletterto.org are not covered by this Privacy Policy. They are covered by the privacy policy of the third-party service (so, when you watch a YouTube video embedded in a anopenletterto.org post, the use of data about your interactions with the video would be covered by YouTube’s privacy policy).

Some embeds may ask you for personal information, such as submitting your email address, through a form linked to from a anopenletterto.org post. We do our best to keep bad actors off of anopenletterto.org. However, if you choose to submit your information to a third party this way, we don’t know what they may do with it. As explained above, their actions are not covered by this Privacy Policy. So, please be careful when you see embedded forms on anopenletterto.org asking for your email address or any other personal information. Make sure you understand who you are submitting your information to and what they say they plan to do with it. We suggest that you do not submit your email address or other personal information to any third-party through an embedded form.

When posting on anopenletterto.org, you may not embed a form that allows submission of personal information by users. You must link offsite to a page that allows such submissions by users, and that page’s appearance must be distinct enough from anopenletterto.org to ensure it does not cause confusion among users over to whom they are submitting personal information. Failure to do so may lead anopenletterto.org to disable the post or take other action to limit or disable your account.

Tracking & Cookies

We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, and personalize content and other services. Cookies are necessary to anopenletterto.org’s basic functionality.

Anopenletterto.org does not track your visits or activities off anopenletterto.org Services. We track your interactions within the anopenletterto.org Services (which encompasses anopenletterto.org, custom domains hosted by anopenletterto.org, and your interactions with our mobile application).

Some third-party services that we use to provide the Service, such as Google Analytics, may place their own cookies in your browser. This Privacy Policy covers use of cookies by anopenletterto.org only and not the use of cookies by third parties.

Modifying or Deleting Your Personal Information

If you have an anopenletterto.org account, you can access, modify or export your personal information on the site or by writing to us at legal@anopenletterto.org.

To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period (generally several weeks). But, if you delete your account, your information and content will be unrecoverable after that time. Anopenletterto.org may preserve and maintain copies of your information beyond this time period when required to do so by law.

Data Security

We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.

Business Transfers

If we’re involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we’ll notify you in advance so you can opt out of any such new policy by deleting your account before transfer.

Email from AnOpenLetterTo.org

Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications through your account’s settings page.

When you interact with an email sent from anopenletterto.org (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction.

We won’t email you to ask for your password or other account information. If you receive such an email, please forward it to us at legal@anopenletterto.org so we can investigate.

Changes to this Policy

Anopenletterto.org may periodically update this Policy. We’ll notify you about significant changes to it. The most current version of the policy will always be available on the anopenletterto.org site.

Questions

We welcome feedback about this policy at legal@anopenletterto.org.

 


2. Data Protection Statement for European Union Users

Description of Processing Activity

Anopenletterto.org collects and stores personal information about its users to customize their reading experience and enable personalized distribution of content. It shares minimal data with its service providers.

Purposes of Processing

  • Provide, test, promote, and improve the Services
  • Gather usage statistics of services
  • Provide customized reading experience
  • Publish and distribute user-generated content
  • Fight spam, fraud, and other abuse of services

Legal Bases

In order to provide the Services, anopenletterto.org collects and stores personal data about its users to fulfill its contractual obligations to users as described in our Terms of Service.

Anopenletterto.org also pursues its legitimate interests by collecting minimal data of logged out users to provide the Services, as outlined above. These legitimate interests are not outweighed by (nor do they violate) our users’ privacy interests because we collect minimal user data for these purposes and we are fully transparent about these activities.

Where anopenletterto.org collects and stores personal data about non-users mentioned in user-generated content, it does so under performance of contract obligations to users who use the Services to publish content on web sites hosted by anopenletterto.org. In such cases, users authoring such user-generated content containing personal data of third parties are responsible for that content. Anopenletterto.org will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.

Public Nature of Personal Data

Logged-in users may choose to interact publicly with the Services by sharing links on connected social media accounts or writing original posts. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of the Services.

Search engines may index your anopenletterto.org user profile page, public interactions, and post pages. Users may also share links to your content on social media platforms such as Facebook or Twitter.

Categories of Personal Data Collected

Logged out users:

  • Reading history
  • IP address
  • Browser information
  • DNT status

Logged in users:

  • Username
  • Display name
  • Bio
  • Avatar image
  • Email address (non-public)
  • Session activity (security)
  • Linked social media accounts (optional)
  • IP address
  • Browser information
  • Reading history (on anopenletterto.org Services only)
  • Posts, responses, or series published by user
  • Billing information and history
  • Bank account for payments
  • Business information, if applicable

Categories of Recipients

Anopenletterto.org shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

  • Hosting, Storage, & Other Infrastructure
  • Security
  • Analytics
  • Communication & Support
  • Payment Processors

Payment Processors

Anopenletterto.org provides Services in conjunction with several payment processors, including: Stripe, PayPal, Google Play, and Apple Pay, through which users may pay for anopenletterto.org services. Those companies acting as payment processors may collect and store personal data related to your billing information and history in order to provide their services, and may collect and store personal data and business data to prevent fraud and other abuse.

When you delete your anopenletterto.org account, anopenletterto.org deletes your personal data as explained in this policy. However, to delete your payment or billing information, you will need to do so with your payment provider, as anopenletterto.org only has minimal secure access to those records as needed to provide the Services.

Use of Algorithms to Personalize User Experience

Anopenletterto.org collects and stores personal data about its users to customize their reading experience by displaying content tailored to the preferences and interests indicated by the users (including through their reading history and Services interactions). This does not constitute automated decision-making as that phrase is used in the GDPR because it does not produce any legal effects or similarly significant effects for users. Anopenletterto.org also moderates content for the purposes of fighting and preventing spam, fraud, and other forms of abuse, and may rely on algorithms as part of doing so.

Potential Consequences of Processing

By creating and using an account on anopenletterto.org, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.

Due to the public nature of information posted to anopenletterto.org, it may be possible for third parties to derive identifying personal data from posts, whether by reading, inference, supplemental research, or automated extraction and analysis.

Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the Services.

Cross-border Transfers

Anopenletterto.org is hosted in the United States. By using the Services, you authorize anopenletterto.org to transfer, store, and use your information in the United States and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

Retention

Anopenletterto.org retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which anopenletterto.org may have limited or no control.

To delete your payment or billing information, you will need to do so with your payment provider, as anopenletterto.org only has minimal secure access to those records as needed to provide the Services.

Rights of Data Subjects

  1. If you sign up for a anopenletterto.org account, you may at any time request an export of your personal information by written request to legal@anopenletterto.org.
  2. You may correct information associated with your account by updating it within your anopenletterto.org account settings or by writing to legal@anopenletterto.org.
  3. You may withdraw consent by deleting your account at any time through written request to legal@anopenletterto.org, which will erase your personal information completely within 14 days (except to the extent anopenletterto.org is prevented by law from deleting your information).
  4. You may object at any time to the use of your personal data by contacting legal@anopenletterto.org. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that post or account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others.
  5. Under EU law you have the right to lodge a complaint regarding the processing of your personal data by anopenletterto.org with the dedicated Supervisory Authority of your EU member state.

Subject Access Requests

For security and account ownership verification reasons, we process Subject Access Requests and account deletion requests from the account holder only. We are unable to process requests made by third-party services.

Contact Information

If you have any questions about this Privacy Policy, you can contact us at legal@anopenletterto.org.

3. Consumer Privacy for California Users

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information,” as described in the CCPA).

This section provides additional privacy disclosures and informs you of key additional rights as a California resident:

Right to Know Request

Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  1. Categories of and specific pieces of personal information we have collected about you.
  2. Categories of sources from which we collect personal information.
  3. Purposes for collecting, using, or selling personal information.
  4. Categories of third parties with which we share personal information.
  5. Categories of personal information disclosed about you for a business purpose.
  6. If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please email us at legal@anopenletterto.org.

Right to Delete Request

Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete if you have an anopenletterto.org account through written request at legal@anopenletterto.org.

Household Requests

We do not knowingly collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

General Requests under CCPA

If you do not have an anopenletterto.org account, we will not have enough information about you to verify your Right to Know and Right to Delete requests since we do not keep sufficient information to reidentify and link you to a prior visit to anopenletterto.org. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

Requests made through Agents

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

In the last 12 months, anopenletterto.org has disclosed certain data from the following categories of personal information to the categories of recipients listed above in the ‘Categories of Recipients’ for one or more business purposes:

Logged in users:

  • Username
  • Display name
  • Avatar image
  • Email address (non-public)
  • Billing information and history
  • Bank account for payments
  • Business information, if applicable

No Sale of Personal Information

Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. At this time and pending final regulations and guidance interpreting the CCPA, we don’t believe any of our data practices constitute a “sale” under the CCPA.

Contact Us

You may contact us by emailing us at legal@anopenletterto.org.