Your privacy is critically important to us. At ALEA, we have a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
• We help protect you from overreaching government demands for your personal information.
• We aim for full transparency on how we gather, use, and share your personal information.

This Privacy Policy applies to information that we collect about you when you use our website and/or newsletter.

Please note that this Privacy Policy does not apply to any of our social networks, like Instagram, that have a separate privacy policy.

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information if and when you provide information to us. Here are some examples:

• Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
• Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with our Happiness Engineers about a support question, post a question in our public forums, or sign up for a newsletter like the one we send through Longreads. When you communicate with us via form, email, phone, aleaspain.org/ comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
• Interactions with other users’ sites: We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed to communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of the association or keep you up to date on our latests news. If you don’t want to hear from us, you can opt out of our communications at any time. (If you opt out, we’ll still send you important updates relating to your membership.)

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:

• Collaborator associations: We may disclose information about you to our collaborators in Erasmus+ Projects, only if you have shown your interest to participate in such project or receive information about it.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of ALEA, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly.

That means information like your public profile, posts, other content that you make public on your website, and your “Likes” and comments on other websites are all available to others — and we hope they get a lot of views!

Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

If you are a member applicant, we will keep your personal data during the application process, and for a certain period thereafter. To determine that period, we take into account a number of factors, like our legal and regulatory obligations and whether we may need to retain personal data for internal business purposes like analyzing our applicant pool.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, premium themes that carry an additional charge — may not be accessible. If you are a job applicant, and you choose not to provide certain data elements to us, we may not be able to proceed with the recruitment process.
• Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Set your browser to reject cookies: At this time, Automattic does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Automattic’s websites, with the drawback that certain features of Automattic’s websites may not function properly without the aid of cookies.

Your Rights

If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Laws in some US states require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).

In the last 12 months, we may have collected the following categories of personal information, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us or you may choose to voluntarily disclose your race or veteran status as part of your job application);
• Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a aleaspain.org/ site);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example, your company and team information if you are a Happy Tools user, or information you provide in a job application); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above.

In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:

• Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion of personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of the sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.

Right to Opt Out

We never directly sell your personal information in the conventional sense (i.e., for money).

We may share your information as necessary with our third-party service providers to provide our services to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a “sale” or “share” in certain U.S. States, which you may have the right to opt out of.

You can learn more about this sharing and how to opt out by clicking the “Do Not Sell My Personal Information” link in the footer of our websites, or from the settings page within our apps. Note that in some instances this link will only display to individuals visiting our sites from within the relevant states.

Our opt-out is managed through cookies, so if you delete cookies, your browser is set to delete cookies automatically after a certain length of time, or if you visit sites in a different browser, you’ll need to make this selection again.

We also respect the GPC browser signal and will treat it as a valid means of communicating your desire to opt out.

We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us through our email (aleaspain [at] proton [dot] me).

Privacy Policy Changes

Although most changes are likely to be minor, ALEA may change its Privacy Policy from time to time. Automattic encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our homepage, or sending you a notification through email or your dashboard). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Credits

This Privacy Policy has been created using the template provided by Automattic. Thank you!