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Privacy Policy

Last updated 10/10/2019

This Privacy Policy explains the information that EnCiv collects when you use any of its applications and website services, how that information is used, with whom it may be shared, and your privacy choices.

1. Introduction

Who we are and what we do

This Privacy Policy covers EnCiv, Inc. and its agents and affiliates who work with it in connection with its online applications and related services (collectively, “EnCiv,” “we” “us” or “our”). Among other services, we provide certain online applications video sharing and related services through our websites and those of our affiliates and our embeddable video players.

Acceptance and Changes

By registering for, downloading, or using our services, you accept this Privacy Policy, which is part of our Terms of Service at https://enciv.org/terms. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at https://enciv.org/privacy/. If we change the Privacy Policy in a way that materially lessens our commitments to you, we will provide notice to registered users by email or other methods.

2. Children’s Privacy

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old to create an account. If you reside in the European Union, you must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater. Individuals under the applicable age may use our services only through a parent or legal guardian’s account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to EnCiv without your consent, you may ask us to delete such information by contacting us at info@enciv.org.

3. Data We Collect About You

We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as “your data” for short.

 

Account Information

To create an account, you must provide a valid email address and password. If you choose to sign-up and/or authenticate using a third-party account (e.g., Facebook, Twitter), you authorize us to obtain account information from the third-party platform.

Content

Accountholders may create a profile and upload certain video content as well as text and photographs, all referred to as “your content” in connection with your profile. Your profile may also display other information about you and your activities. This information may be accessed by others. Your videos and your content may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, descriptions, tags, etc.) are viewable by others. Your interactions with other users (e.g., comments, “likes,” private messages) may be seen by others.

Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; or signing up to receive communications from us or another user.

Automatically-Collected Information

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our Cookie Policy at https://enciv.org/cookie_policy

Residential Location

In connection with your account, and for our internal use only, we ask you to provide your residential location (street address, city, county, state). This will allow us to determine the relevant legislative districts to you, and will help us detect fraudulent account creation.

Information Collected by Third Parties

Some third parties may collect data about you when you use our services. This may include data you submit or automatically-collected information (in the case of third-party analytics providers and advertisers).

We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.

 

4. How We Use Your Data

We may use your data for the following purposes:

  • Identification and authentication: We use your data to verify you when you access your account.
  • Operating our services: We use your data to provide our services and user support in connection with those services.
  • Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).
  • Improving our services: We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).
  • Customizing your experience: We may use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying videos that you might enjoy, based upon your viewing choices.
  • Marketing and advertising: We may use your data to display ads and send you offers. We may also use your data in delivering third-party advertisements to you. This may include “targeted ads” based upon your activities.
  • Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.
  • Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.
  • Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.

We may use algorithms and other automated means to implement any of the above.

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

  • Performance of our services;
  • Legitimate commercial interest;
  • Compliance with a legal obligation; or
  • Consent

If you require further information about the balancing test that EnCiv has undertaken to justify its reliance on legitimate interest as a lawful basis of processing, see Section 14 for information on how to contact us.

 

5. With Whom We Share Your Data

We share data with third parties as follows:

  • As you instruct: We may make your profile and your content available to others as you instruct in using our services. We may share your data with persons to whom you have granted account-level access.
  • With your consent: We may share your data with third parties where we have obtained your express consent to do so. You may revoke these consents.
  • Authorized vendors: We may share your data with third-party vendors that help us operate our services, and comply with your instructions and our contractual obligations. This includes content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, and customer relations management (CRM) vendors.
  • Advertising: We may share your data with advertising companies to display relevant ads to you. Unless you expressly agree, we will not share or sell your name, email address, or physical address with such companies.
  • Analytics: We may share your data with companies who provide analytics showing how customers are using our services.
  • Affiliates and advisors: We may share your data with one or more affiliates or advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. Unless you expressly agree, we will not share your data with any affiliate for other purposes, such as direct marketing.
  • Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction as discussed in Section 6.
  • Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.

We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

6. Legal and Safety-Related Disclosures

We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) (“requests”) that we receive from government authorities or parties to legal proceedings. We may also disclose user data to report suspected crimes.

We handle U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.

We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

7. Data Retention

We retain your data for as long as you have an account. When you close an account, we will delete your personal information. Contributed content, however, is relied upon by other users as building blocks of conversations, and sometimes the basis of their decisions. We will only delete contributed content when (i) you specifically identify it (with a link), request deletion and explain why you are requesting deletion; and (ii) we determine, on a case-by-case basis and in our sole discretion, that such deletion is merited. We may retain logs of automatically collected information (for internal analytics); your email address; and communications with you. When we no longer have a business reason for retaining data, we will delete or anonymize it.

If we do elect to delete content, whether due to your breach of our Terms of Service or for any other reason, in our sole discretion, the content or its thumbnail may be discoverable in a search engine’s cache for a time.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

8. Your Privacy Choices

We enable you to make some choices about your data:

  • You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.
  • You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.
  • You may limit the use of cookies. See our Cookie Policy at https://enciv.org/cookie_policy for options.
  • You may close your account, which will delete your account information, but submitted content may be retained unless you request it pursuant to the terms of section 7, above.

Users from certain countries may have additional rights. See Section 13 for more details.

9. Communications from Us

Emails

By creating an account, you consent to receive emails from us.

Mobile Device Communications

We may, with your consent, send push notifications in our apps. You may disable these by declining them or changing the app’s settings. To the extent provided, we may, with your consent, send SMS messages to your mobile telephone for authentication and security purposes. You may opt out of receiving such messages at any time.

10. Protecting Your Information

We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

11. Your Responsibilities

You may receive other people’s data in using our service. If you receive information from other users, you must comply with all laws, including those concerning privacy, data security, and online marketing.

12. Third-Party Services

We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. For example, if you click on an advertisement, you may be taken to the advertiser’s website. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.

You may use our service through third-party sites. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps and video players, but does not cover any third-party site or any third-party video player.

13. International Data Transfers and Certain User Rights

13.1 International Data Transfers

EnCiv is based in the United States. We provide services globally using computer systems, servers, and databases located in the U.S. and other countries. When you use our services from outside of the U.S., your information will be transferred to, stored in, and processed in the U.S. and other countries. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of the European Economic Area and certain other countries may be subject to additional protections, including the EU’s General Data Protection Regulation (GDPR), EU-U.S. and the Swiss-U.S. Privacy Shield frameworks. With respect to International users, and to the extent reasonably possible, it is EnCiv’s policy to comply with the applicable provisions of the GDPR and the EU-US and Swiss-U.S. Privacy Shield frameworks and principles.

In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:

  • Legitimate business interests: We could not provide our services or comply with our legal obligations without transferring your personal information to the U.S.
  • Our use of Standard Contractual Clauses (also known as “Model Clauses”) where appropriate.
  • Our adherence to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, as described further below.

If you are a resident of the European Union, the United Kingdom, or Switzerland, you may have the right to: opt out of non-essential cookies (see our Cookie Policy at https://enciv.org/cookie_policy); access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily in response to direct user requests, including user requests that their accounts be closed, their personal data be removed, and their contributed content be taken down. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person’s rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry concerning the regulations and policies referenced in this section 13.1, please contact us at the address listed in Section 14. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

13.2 California User Rights

California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure. If you have questions, please contact us.

13.3 Nevada User Rights

Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, you can provide us with your name and email address here. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this privacy policy. We may share your data as explained in this privacy policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request.

14. How to Contact Us

For any questions, inquiries, or complaints relating to your privacy, please send us our message through our contact page: https://enciv.org/contact

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