Last updated 16 March 2021.
Thank you for choosing to be part of our community at Accord Cooperative (“Cooperative”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
1. What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering with the Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Publicly available personal information
We collect preferred names, phone numbers, email addresses, social media handles and profiles, and other similar data.
We collect security information used for authentication and account access to third-party Apps only with your consent. We collect a password for authentication and account acces with our own Apps.
Social media data
Some of our Apps can be used on social media platforms (such as Facebook). If you choose to interact with our Apps on those platforms, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.
Information automatically collected
In Short: Some information, such as IP address and/or browser and device characteristics, is collected automatically when you use our Apps.
We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
We collect device; applications; tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics and communications; and other similar data.
Information collected through our Apps
In Short: We may collect information regarding your mobile device, push notifications, and Facebook permissions when you use our apps.
If you use our Apps, we may also collect the following information:
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s calendar, reminders, SMS messages, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Facebook Permissions. We may access your Facebook basic account information, including your name, email, and profile picture URL, as well as other information that you choose to make public. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
2. How do we use your information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process: If you choose to link your account with us to a third party account (such as your Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
To send you educational and promotional communications: We and/or our third party partners may use the personal information you send to us for our communications purposes, if this is in accordance with your communications preferences. You can opt-out of our communications at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
To send administrative information to you: We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Request Feedback: We may use your information to request feedback and to contact you about your use of our Apps.
To protect our Services: We may use your information as part of our efforts to keep our Apps safe and secure (for example, for fraud monitoring and prevention).
To enable user-to-user communications: We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.
To deliver services to the user. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
For other Business Purposes: We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our educational material and to evaluate and improve our Apps, products, communication and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. Will your information be shared with anyone?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers: We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and communication efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of Cooperative assets, financing, or acquisition of all or a portion of our business to another business entity.
Other Users: When you share personal information (for example, by posting comments or other content to the Apps) or otherwise interact with other users on the Apps, such personal information may be viewed by users with access to that information in perpetuity. If you interact with other users of our Apps on a social media platform (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.
4. Who will your information be shared with?
In Short: We only share information with the following third parties.
Cloud Computing Services
- Google Cloud Platform (“GCP”) (Google LLC)
Communication with Users
- Sendgrid (Twilio Inc.)
- Typekit (Adobe Inc.)
Functionality and Infrastructure
User Account Registration and Authentication
- Slack (Slack Technologies, Inc.)
Website Performance Monitoring
- GCP Logging (Google LLC)
6. How do we handle your social logins?
In Short: If you choose to use our Apps on a social media platform, we may have access to certain information about you.
Our Apps are made available on certain social media platforms, which can be accessed through those platforms’ app marketplaces. If you choose to access our Apps on a social media platform, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, list of friends or coworkers, profile picture as well as other information you choose to make public. We may also request access to other permissions related to your account, and you may choose to grant or deny us access to the individual permissions the platform makes available.
7. Is your information transferred internationally?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in EU member states. If you are accessing our Apps from outside the EU, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above).
In the event of a transfer of data, we ensure that the recipient of your data offers an adequate level of protection, for instance by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).
8. How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. How do we keep your information safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. For example, communication between our systems and to your user agent (your browser or mobile device) are encrypted using TLS, SSL, or HTTPS, and any unencrypted access is denied.
Although we will do our best to protect your personal information, however, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment using devices you trust.
10. Do we collect information from minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
11. What are your privacy rights?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right:
- to request access and obtain a copy of your personal information;
- to request rectification or erasure;
- to restrict the processing of your personal information; and
- if applicable, to data portability.
In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- log into your account settings and update your user account, or
- contact us using the contact information provided.
Cookies and similar technologies
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Apps.
Opting out of email communications
You can unsubscribe from our communications email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the communications email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
- note your preferences when you register an account with the site, or
- access your account settings and update preferences.
12. Data breach
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Accord Cooperative believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Accord Cooperative becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Accord Cooperative will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
13. Controls for do-not-track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We will make every reasonable effort to honor DNT requests in our Apps.
14. Do California residents have specific privacy rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at firstname.lastname@example.org.
If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
15. Do we make updates to this policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
16. How can you contact us about this policy?
If you have questions or comments about this policy, you may contact Will Shown, Accord Cooperative’s director-member responsible for data protection, by email at email@example.com.