Privacy Policy

Last updated: May 25, 2021.

This Privacy Policy sets out Transparentem Ltd.’s (“Transparentem,” “we,” “us,” or “our”) policies regarding the collecting and processing of personal data through our website, located at www.transparentem.com (the “Site”). By visiting our Site, using our Site, and, subscribing to our newsletter or donating to us, you agree to the terms of this Privacy Policy.

If you are a Nevada Resident, California Resident, or a data subject in Europe, please see respectively the “Additional Disclosures for Nevada Residents,” “Additional Disclosures for California Residents,” and “Additional Disclosures for People in Europe” sections below. If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.

A. Information We Collect

A. Information We Collect
In the course of operating the Site, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Personal Information
Transparentem collects personal data about you when you

visit the Site;
subscribe to our newsletter or other online publication, or
make a donation.

When you subscribe to publications or make a donation, you will be required to provide us with personal information about yourself, including your name, address, e-mail address, and phone number, and other identifying information about yourself. If you contact us, you will need to provide your name and e-mail address. All information we collect and/or receive under this section is collectively called “Personal Information.”

When you visit our Site, we may automatically collect other information about you, which may not directly identify you, but which may correspond with you or a particular device or IP address, including some geolocation information. We use this information to learn more about how our Site is used and to otherwise improve and administer the Site. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Further information about our use of cookies can be found below in the Cookies and Other Information section in this Privacy Policy.

2. Billing Information.
When you wish to make a donation, you will be required to provide certain information to our third-party payment vendor pursuant to the terms and conditions of their privacy policies and terms of use. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called the “Billing Information.” You authorize our third-party payment vendor to collect, process, and store your Billing Information. Transparentem does not store or process your Billing Information. Our payment partners retain and store your personal data according to the partners’ privacy policies, which you may find by clicking https://stripe.com/privacy.

3. Cookies and Other Information.
In addition to the information noted above, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

a. From You. Additional information about yourself that you voluntarily provide to us and other information that does not identify you personally.
b. From Your Activity. Information that we automatically collect when you use the Site, including, without limitation:

IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Site you visit; and similar data; and
Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Site. If you do not want us to place a cookie on your hard drive, you can generally turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies.
Third-Party Analytics. We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

B. How We Use and Share the Information

We use the Personal Information and the Other Information (collectively, the “Information”) to maintain and improve our Site; to solicit your feedback; and to inform you about our activities, and for any such other uses as may be allowed by applicable law.

We may also use and/or share Information as described below.

Company will access, use, and share the Information as required to process your donations, if applicable, and provide support to you.
We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, and payment processing. These other companies will have access to the Information as necessary to perform their functions and to the extent permitted by law.
In an ongoing effort to better understand our visitors and our services, we may analyze Information in aggregate form in order to operate, maintain, manage, and improve the Site. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates. We may also disclose aggregated user statistics in order to describe interest in our Site and our activities to current and prospective donors, and to other third parties for other lawful purposes.
We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our activities, we might divest some of our assets or our organization or acquire other organizations or assets of other organizations. In the event of such a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of Transparentem or others.

C. How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

D. International Transfer

It is important to note that the Site and their servers are operated in the United States. If you are located outside of the United States, please be aware that any Information you provide to us including personal information will be transferred, processed, stored and used in the United States. Data protection laws in the US and other jurisdictions may be different than those in effect in your country of residence.

E. Children

We do not knowingly collect Personal Information from children under the age of 13 through the Site or Products. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the Site or Products without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

F. Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing the Site and/or using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

G. How to Contact Us

If you have questions about this Privacy Policy, please contact us via e-mail at info@transparentem.com with “Privacy Policy” in the subject line or write to us at:

    Transparentem Ltd
    347 Fifth Avenue
    Suite 1402-443
    New York, NY 10016

H. California Residents

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal data the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at info@transparentem.com or by writing to us at:

    Transparentem Ltd
    347 Fifth Avenue
    Suite 1402-443
    New York, NY 10016

I. Additional Disclosures for Data Subjects in Europe

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”).

Transparentem acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.

Lawful Basis for Processing.

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

Data Transfer.

If your data is collected in Europe, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses, or pursuant to applicable derogations such as your consent to data transfer or our need to transfer your data for purposes of fulfilling our obligations to you and providing you services.

Your Data Subject Rights

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please allow us a reasonable time to respond to your inquiries and requests. You may exercise your rights by sending an email to info@transparentem.com, and we will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your requests. If we decline your request, we will tell you why, subject to legal restrictions.

Retention of Personal Data

We will retain your personal data in a form that identifies you to fulfill the purposes for which it was collected. We may continue to retain and use information even after a data subject request for purposes of our legitimate interests, such as journalism, literature and art, scientific or historical research, statistical analysis, compliance with our legal obligations, resolving disputes, preventing fraud, and enforcing our agreements.

Complaints

If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. To do so, please use the contact information set out above.