Effective Date of Current Policy: October 5, 2018
TRANSPARENCY/NOTICE—Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Wogrammer and the requirements of applicable law. Some of the ways that Wogrammer may collect Personal Information include:
You may provide Personal Information directly to Wogrammer through interacting with the Services, participating in interviews, participating in surveys, and requesting Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Types of Personal Information We Collect
Wogrammer collects Personal Information regarding its current, prospective, and former volunteers, fellows, board members, advisors, others visitors, guests, and Employees (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as requesting Services or information, participating in an interview or contacting us directly, we may ask you to provide some or all of the following types of information:
Communications with Us. We may collect Personal Information from you such as email address, name, job title, education and employment background when you choose to request information about our Services, register for Wogrammer’s newsletter or, submit a nomination form, participate in an interview, or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
Posting on the Site. Wogrammer may offer publicly accessible pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Wogrammer’s pages, blogs, private messages, and community forums, the Services will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Registration for Journalism Fellowship. We ask those who apply to provide contact and education information such as an e-mail address, a current resume, and a writing sample. If you are selected for a fellowship, we may ask for some additional information in order to process your compensation.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
How Wogrammer Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Services, or Information Requested. Wogrammer may use information about you to provide the services, or other information, including to:
Generally manage Individual information;
Respond to questions, comments, and other requests;
Consider your nomination for interview and your fellowship application;
Provide access to certain areas, functionalities, and features of Wogrammer’s Services;
Allow you to register for events.
Administrative Purposes. Wogrammer may use Personal Information about you for its administrative purposes, including to:
Measure interest in Wogrammer’s Services;
Develop new Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual activities on Wogrammer’s Services and systems, and, in Wogrammer’s discretion, changes to any Wogrammer policy;
Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as customer service, or system maintenance;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Wogrammer Services. Wogrammer may use Personal Information to provide you with materials about offers, and Services that may be of interest, including new content or Services. Wogrammer may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Other purposes with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development. Wogrammer may use Personal Information alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. We may share de-identified Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Wogrammer’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
De-Identified and Aggregated Information Use. Wogrammer may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Wogrammer’s Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not Personal Information, and Wogrammer may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Wogrammer and with Third Parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Wogrammer’s Services may offer various tools and functionalities. For example, Wogrammer allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Wogrammer or any other Third Parties for any other purpose.
Other Uses. Wogrammer may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and other vendors to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Wogrammer does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Wogrammer’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
Human Resources Data
Wogrammer collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
Workflow management, including assigning, managing and administering projects;
Human Resources administration and communication;
Payroll and the provision of benefits;
Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
Job grading activities;
Performance and Employee development management;
Organizational development and succession planning;
Benefits and personnel administration;
Helpdesk and IT support services;
Internal and/or external or governmental compliance investigations;
Internal or external audits;
Litigation evaluation, prosecution, and defense;
Diversity and inclusion initiatives;
Restructuring and relocation;
Emergency contacts and services;
Compliance with statutory requirements;
Processing of Employee expenses and travel charges; and
Acquisitions, divestitures, and integrations.
Onward Transfer—Wogrammer May Disclose Your Information
Information We Share
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Wogrammer has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. Wogrammer may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Wogrammer may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Wogrammer. Wogrammer requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Wogrammer provided them.
Displaying to Other Users. The content you post to the Services may be displayed on the Services. Other users of the Services may be able to see some information about you, such as your name, employment and education. We are not responsible for privacy practices of the other users who will view and use the posted information.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Wogrammer may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Wogrammer related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce Wogrammer policies or contracts; (v) to collect amounts owed to Wogrammer; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
All Personal Information collected via or by Wogrammer may be stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Wogrammer, you consent to the storage of your Personal Information in these locations.
Opt-Out (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Wogrammer’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes.
Email and Telephone Communications
Human Resources Data
With regard to Personal Information that Wogrammer receives in connection with the employment relationship, Wogrammer will use such Personal Information only for employment-related purposes as more fully described above. If Wogrammer intends to use this Personal Information for any other purpose, Wogrammer will notify the Individual and provide an opportunity to opt-out of such uses.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
Rights of Access, Rectification, Erasure, and Restriction
Although Wogrammer makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Wogrammer is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Wogrammer determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Wogrammer will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Security of Your Information
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age (“Children”), and Wogrammer does not knowingly collect Personal Information from Children. If you are under the age of 18, you must have your parent’s permission to access the Services. Wogrammer urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your Child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Information from Children, we will promptly take steps to delete such information and terminate the child’s account.
Redress/Compliance and Accountability
Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Wogrammer will endeavor to comply with the law or contract.
California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Wogrammer or to which Wogrammer discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Wogrammer or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Wogrammer or Wogrammer’s Agents.
You can write to us at: Wogrammer, Inc. 487 Oak Ridge Drive Redwood City, CA 94062