Privacy | Openpolicy

Open Policy's Website and Platform Privacy Policy

Last Revised: May 2, 2024

Open Policy Inc. and its affiliates (“Open Policy”, the “Company”, “us”, “our” or “we”) respect the privacy of its Website and Platform users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our website at https://openpolicygroup.com/ and its subdomains (the “Site”) and/or our Platform and Services (as such term is defined in our Terms of Use). Please read the following carefully to understand Open Policy’s views and practices regarding your personal information and how Open Policy will treat it.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at https://openpolicygroup.com/terms-of-use (“TOU”), into which this Privacy Policy is incorporated by reference.

Who we are

In this policy, references to Open Policy, or to the “Company”, “we”, “ours” or “us” are to Open Policy Inc. and its affiliates, which is a registered company in the state of Delaware, having its principal office at 200 Massachusetts Ave NW, Washington, DC 20001, United States. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at legal@openpolicygroup.com.

Your acknowledgment of this policy

This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site and/or the Services and/or the Platform is used and processed by Open Policy.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR THE SERVICES AND/OR THE PLATFORM, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND OPEN POLICY’S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY.

Which information may we collect about Users?

We collect from Users of our Site, two types of data and information:

Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).

You may access and browse the Site and/or the Services and/or the Platform without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site/Platform, the activities of the User on the Site/Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers, such as Google Analytics, to obtain detailed analytics on the device and the User's behavior on the Site and Platform. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.

Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including: name, email address, phone number.some text
1. Personal Information which is provided voluntarily:

Communications with Open Policy: Personal Information you provide us as part of any communications with Open Policy, by any means, including by contacting us via the Site or email, approaching our customer services, or during sales calls or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Please note that we may record calls for quality assurance purposes and in order to improve our services.
Contact Details: Personal Information is collected from the details the Users provide in the "Contact Us" tab available on the Site. Such Personal Information includes your full name and email address. You may provide via the contact form your telephone number and any text you wish to insert into the “leave us a message” box. Additional information may be requested via the contact form in the future.
Mailing list: you may voluntarily join our mailing list by providing us with your full name and email address via our Site.
Account: Personal Information is collected from the details Users provide in the registration form in order to open an Account, which includes, inter alia, the User's full name, phone number, email address, name of organization, role, etc. To this end, we may require additional information from time to time.
User Data: When you use the Platform, you may upload, store, or share User Data that contains Personal Information about yourself or others. You are solely responsible for ensuring that you have the right and authority to upload, store, or share any User Data that contains Personal Information, and that you have obtained all necessary consents, permissions, and notices from any third parties whose personal information is included in your User Data.
Use of the Platform: We derive some Personal Information from your interactions with the Platform, such as your interests, membership in Collations, comments, ratings, feedback, and participation in surveys, contests, or promotions.
Payment: to collect any fees and payments due in connection with your use of the Services and/or the Platform, you will be required to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see Section 6 below regarding the payment method). We will not store such information on our servers and will only keep token information such Online Payment Processors provide us with.

Personal Information collected via technology:

Geolocation data: during your visit to the Site and/or Platform we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address and other similar data, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse to our Site, for the purpose of locating prospects and in order to analyze our Site's traffic.
Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section ‎3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers for security purposes, analytics and in order to provide you with targeted advertising of our products and services.

Information from other sources:

Public Sources. We obtain information from other sources, which may include, but not limited to, publicly-available sources, information provided by third parties which helps us determine your location based on your IP address and data providers, such as Google Analytics, from which we obtain demographic, interest based and online advertising related data.
Coalitions. We may also collect Personal Information about you from third parties that are members of a coalition that you joined through our Platform or Services. For example, if you join a coalition that advocates for a certain cause or issue, we may receive information from other coalition members about your participation, preferences, feedback, or donations. We use this information to provide you with relevant content, opportunities, and communications, as well as to measure and improve the effectiveness of our Platform and Services.

Please note:

We may cross-reference your Personal Information with other Personal Information we may have about you. Any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and Platform and for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and Platform and the information for which you searched and accessed.

How do we collect information about our Users?

There are a few main methods we use to collect information:

We collect information through your entry, connection, access and/or use of the Site and/or the Services and/or the Platform. In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site or Platform, we gather your Technical and Behavioral Information.
We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the "Contact Us" form on our Site.
We collect information from third party sources. We may collect information relating to you from other members of any Coalition that you joined.

What are the purposes of the collection and processing of information? some text
1. Non-personal Information is processed in order to: some text
  - Enhance the User’s experience on the Site and/or the Services and/or the Platform;
  - Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
  - Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity.

Personal Information is processed in order to:

Enable the operation and constant improvement of the Site and/or the Services and/or the Platform;
Collection of fees and payment;
Formulating, customizing and enhancing the User's experience on the Site and/or the Services and/or the Platform;
Send push notifications to Users. Users of the Platform can deactivate push notification by changing their settings within our Platform or by using their web browser/device’s settings;
Verify the User's identity when they sign into the Services;
Be able to contact Users for the purpose of providing them with technical assistance and support;
Determine the User’s geo-location to safeguard the Site and/or the Services and/or the Platform;
Register your interest in our products and services;
Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;
Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone or through web-browser notification. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: legal@openpolicygroup.com. For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing;
Personalize your experience on the Site and/or the Services and/or the Platform;
Ensure that content on the Site and/or the Services and/or the Platform is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;
Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity;
Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests;
To conduct internal research;
Maintain our data processing records and general administrative purposes; and
Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.

Payments

We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. Open Policy is not affiliated with such Online Payment Processors (for more information see our Terms), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User's discretion and sole liability and risk. It is the User's responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

Sharing Personal Information with Third Partiessome text
1. Open Policy respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.
2. In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:

Open Policy Personnel and Affiliates: Personal Information that we collect and process may be transferred to or accessed by personnel of Open Policy and its affiliates for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section ‎5 above). Please note that all Open Policy personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site and/or the Services and/or the Platform. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 12 below.
In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and Open Policy, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Open Policy, its Users or the general public; and (e) when Open Policy is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Open Policy (while such acquired company or investor may be located in countries outside of your jurisdiction); (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; or (g) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Open Policy may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site and/or the Services and/or the Platform.

Your Rights

Open Policy acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please use the functionality available via the Platform or send us an email to: legal@openpolicygroup.com and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Location of Your Data

The information collected from you by Open Policy, as detailed in this Privacy Policy, may be transferred to, and stored in, servers which may be located in countries outside of your jurisdiction and in countries that are not considered to offer an adequate level of protection under your local laws. It may also be processed by Open Policy and its suppliers, service providers or partners' staff operating outside your country.

Open Policy is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps may include, but not limited to, putting in place data transfer agreements and ensuring our third-party service providers comply with Open Policy's data transfer protection measures.

BY SUBMITTING YOUR PERSONAL INFORMATION TO OPEN POLICY, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

Social Features

Our Site may include social media features, such as Facebook, Twitter, LinkedIn and WhatsApp links (“Social Features”). The Social Features are operated or allow for social integration with certain third party social networks or third party Sites ("Social Network"). These Social Networks are created and maintained by third parties who are not affiliated with and/or controlled by Open Policy. If you enable this integration with such Social Networks, your use of the Social Features is subject to the applicable third party Social Network’s terms of use and privacy policies. You should ensure that you read their terms of use and privacy policies to understand how they treat your information and in order to understand the methods for changing the privacy or sharing settings on such services. If you do not agree to the practices described in such terms you should not allow the Site to interact with such Social Networks, however you may find that you are not able to enjoy all the features that may be made available via the Site. You understand that where you allow interaction with any third party Social Network, we may share data about you with your contacts (and vice versa) in order that you may enjoy social elements. This data may include, inter alia, your name and your social media profile picture. By using the Social Features, you hereby agree and understand that the applicable Social Networks may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features. You hereby understand and agree that when you share content from Social Networks, your content may become public and others may repost it.

Minors

The Site and/or the Services and/or the Platform are intended for Users over the age of sixteen (16). Therefore, Open Policy does not intend and does not knowingly directly collect any Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site and/or the Services and/or the Platform.

Third Party Service Providers some text
1. During your visit to our Site, we may use third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy.
2. Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.
3. Note, that we collect, hold and/or manage your Personal Information through Open Policy's authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
4. Such vendors may be located in countries that do not have the same data protection laws as the laws applied in your jurisdiction.
5. Such third parties service providers may include without limitation the following categories of service providers: Hosting providers, Analytics services, Authentication services, Monitoring service providers, Email Delivery services, generative AI technologies.
Links to Third Party Websites

The Site and/or the Services and/or the Platform may contain certain links permit Users to leave our Site and/or the Services and/or the Platform and enter non-Open Policy sites or services. Most of such linked sites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected. The Company is not responsible for the privacy practices or the content of such resources.

Security some text
1. We take reasonable measures to maintain the security and integrity of our Site and/or the Services and/or the Platform and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
2. Your Personal Information is hosted on third party servers, which provide advanced strict security standards (both physical and logical).
3. Some of the security measures that we employ include, without limitation: the application of highly secure design and implementation methods to all our Services, including state of the art encryption mechanisms and secure architecture design to all storage and transmission mechanisms used for the processing and transmission of your Personal Information, as well as access control and auditing systems (including firewall and identity management solutions), that restrict access to your Personal Information to authorized personnel only, based on their roles and their need-to-know requirements, needed to process your Personal Information on Open Policy’s behalf.
4. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
5. Open Policy will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach as required by applicable law.
6. TO THE EXTENT THAT OPEN POLICY IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, OPEN POLICY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
Data Retention

Open Policy will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site and/or the Services and/or the Platform and any information collected with respect thereto. Open Policy reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or the Platform or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site and/or the Platform or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site and/or the Services and/or the Platform on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: legal@openpolicygroup.com, and we will make an effort to reply within a reasonable timeframe.

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