Last Updated: 11, February, 2021

PRIVACY POLICY

INTRODUCTION

Intercultural Roots (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.interculturalroots.org, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully.  If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy.  Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.  

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you choose to participate in various activities related to the Site, such as online chat and message boards. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data

Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, all financial information is stored by our payment processor, Stripe, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Facebook Permissions  

The Site may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

Data from Social Networks

User information from social networking sites, such as [Apple’s Game Center, Facebook, Google+, Instagram, Pinterest, Twitter], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Third-Party Data

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

Data from Contests, Giveaways, and Surveys

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  Specifically, we may use information collected about you via the Site to:

●      Administer sweepstakes, promotions, and contests.

●      Assist law enforcement and respond to subpoena.

●      Compile anonymous statistical data and analysis for use internally or with third parties.

●      Create and manage your account.

●      Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.

●      Email you regarding your account or order.

●      Enable user-to-user communications.

●      Fulfill and manage purchases, orders, payments, and other transactions related to the Site.

●      Generate a personal profile about you to make future visits to the Site more personalized.

●      Increase the efficiency and operation of the Site.

●      Monitor and analyze usage and trends to improve your experience with the Site [and our mobile application].

●      Notify you of updates to the Site.

●      Offer new products, services, mobile applications, and/or recommendations to you.

●      Perform other business activities as needed.

●      Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

●      Process payments and refunds.

●      Request feedback and contact you about your use of the Site.

●      Resolve disputes and troubleshoot problems.

●      Respond to product and customer service requests.

●      Send you a newsletter.

●      Solicit support for the Site.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:  

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Interactions with Other Users

If you interact with other users of the Site, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

Online Postings

When you post comments, contributions or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include partner charity (Intercultural Roots for Traditional Embodied Arts) and any other charities/companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Social Media Contacts  

If you connect to the Site through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.

Internet-Based Advertising

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.  For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Website Analytics

We may also partner with selected third-party vendors[, such as Google Analytics and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

PRIVACY CONSIDERATIONS WHEN USING ZOOM

Intercultural Roots uses Zoom for online events.  You are hereby notified and informed that Intercultural Roots may record such events and edit such recordings for the purpose of promotion and sale. We do this via Zoom cloud recording and download such recordings subsequent to meetings. You can read Zoom’s own privacy policy in terms of how they use personal data when they host meetings here. Such recordings may include your image and background, voice, chat messages and other ways in which your personal information might be captured. Additionally, Intercultural Roots receives from Zoom and stores attendee lists and other information related to participation in Zoom meetings. Often people are not aware of Zoom’s ability to even tell whether someone is paying attention or not! By way of this document, Intercultural Roots is making it clear to Zoom event attendees we may record sessions and/or transcripts which may be shared publicly. This has implications for your privacy (e.g. if you turn on your camera your image will be available to everyone in attendance, and depending on how you set up your account, your name, email, etc. may be available to other attendees, and what you say will be recorded.  If you screen share or discuss confidential information, this too may be retained as part of the recording, so please be mindful of your own privacy requirements. We will download such recordings from the Zoom cloud to our file store (i.e. Dropbox, Google Drive etc) and uploaded edited versions of videos to Vimeo, YouTube, Facebook, Instagram, Twitter and other sharing platforms.

A. Purpose and Principles

Zoom is one of the primary approved software tools for online events. This section of our Privacy Policy provides basic guidance on how to protect your privacy and the privacy of others when using Zoom. The use of remote delivery software and technologies such as Zoom heightens the criticality of privacy and the need to use the least invasive means of delivering our activities. Existing law and policy that address privacy remain in effect when we work remotely.

All Intercultural Roots staff, practitioners and participants should follow these principles when using Zoom to conduct remote meetings:

B. Technical Tips and Privacy Protections for Video Conferencing

1. Visibility of your locations:  Participants should use Zoom’s virtual background feature, when available, if they do not want to have their surroundings visible.  Hosts should encourage participants to use Zoom meeting settings that allow living areas to remain hidden.  

A. To set up a Virtual Background in Zoom (link is external) click the up arrow by the Zoom video icon and click on “Choose Virtual Background”.

B. Select only appropriate virtual backgrounds.

C. Be mindful of others in your remote location who may not wish to be visible or recorded in the background.

D. Also consider if all participants need to be visible as limiting the meeting to a single video stream can ease bandwidth concerns for participants.

E. Ensure sensitive conversations cannot be overheard or work observed by unauthorized persons.

2. Screen Sharing Privacy

A. Protecting Confidential Data on Your Device from Being Viewed: Avoid sharing confidential information visible on your other screens.  Before screen sharing, close all applications, emails and documents that you will not use in that session.

B. Managing Whose Screen is Visible (link is external):Zoom default settings for Intercultural Roots are set to limit screen sharing to the host. The host can also allow screen sharing by participants.  Options are available by clicking on the up arrow by the Share Screen icon. The host can select the “host only” setting to prevent others from sharing their screens. If the host determines that screen sharing by participants is needed, sharing by “one participant at a time” should be selected.  The host should remind participants not to share other sensitive information during the meeting inadvertently.

3. Managing Participants

Some basic tips for limited preventing unwanted attendees or Zoom Bombing are listed below:

A. Don’t post meeting IDs in public forums.

B. Don’t reuse meeting access codes. You can generate a new access code for each meeting.

C. Monitor participant list for unwanted attendees

D. Using Zoom settings for meeting participants (link is external), the meeting host can:

i. Limit attendance to participants who are signed in to the meeting (link is external) using the email listed in the meeting invited

ii. Set up a Waiting Room Function (link is external)

iii. Password protect (link is external) meeting access

iv. Lock meetings (link is external) once they start

v. Mute participants (link is external) who are not presenting

vi. Remove unwanted participants (link is external)

vii. Disable private chat

For further privacy features and options for Zoom see: https://blog.zoom.us/wordpress/2020/03/20/keep-the-party-crashers-from-crashing-your-zoom-event/ (link is external)

C. Recording of Zoom Meetings and Chats

Recording of Meetings – by attending an Intercultural Roots Zoom meeting or event you are providing Intercultural Roots permission to capture your video and save information relating to the session. Where possible we will make this explicit as “two party” or “all party” consent to ensure agreement between both or all parties involved in a recording. While attendees participating remotely may be coming from a variety of countries and states, we assume an “all party” consent rule.

Meeting hosts should always inform attendees at the start of the meeting or in advance of the meeting that they are going to record a meeting.   Zoom automatically notifies attendees present at the start of a meeting if the meeting is being recorded.  However, meeting hosts should also verbally notify attendees that a meeting will be recorded.  Meeting hosts may also choose to explicitly require consent to be recorded via Zoom (link is external).  Attendees who do not consent will be denied access to the meeting, so we suggest its use only after you’ve communicated with your attendees, given them a chance to express any concerns, and determined an alternative for individuals who have not consented.

We recommend that you inform meeting attendees, prior to a recorded meeting, how you intend to record, use, and share video. You may also consider giving attendees options to participate without having their image or voice recorded, such as allowing them to attend with no video or audio, and the option to pose questions only in the text chat window. Because you can start and stop recordings in Zoom at any time, you can choose to include unrecorded time throughout your Zoom session, giving attendees an opportunity to discuss topics or ask questions that they do not wish to have recorded.

As a general rule, Intercultural Roots meetings that involve discussions of a personal nature should not be recorded absent an articulated purpose that requires recording of the meeting.  Generally, you should not record a meeting if the same meeting would not be recorded if it occurred in person.

Hosts should inform attendees that the meeting is being recorded and offer attendees the opportunity to opt out of the meeting or to mute their audio and video if they object to the recording of their image or voice.  Please note that Intercultural Roots recordings become a record that will be stored and retained appropriately and may be subject to disclosure upon request (e.g., in response to an official request).  

D. Disability Accommodations

For guidance regarding accessibility and Zoom, see Zoom Accessibility Considerations page (link is external).

E. Privacy Data Protections with Zoom

Zoom’s Updated Privacy Policy (link is external) states:

We do not sell your personal data. Whether you are a business or a school or an individual user, we do not sell your data.  

• Your meetings are yours. We do not monitor them or even store them after your meeting is done unless we are requested to record and store them by the meeting host. We alert participants via both audio and video when they join meetings if the host is recording a meeting, and participants have the option to leave the meeting.  

• When the meeting is recorded, it is, at the host’s choice, stored either locally on the host’s machine or in our Zoom cloud. We have robust and validated access controls to prevent unauthorized access to meeting recordings saved to the Zoom cloud.

• Zoom collects only the user data that is required to provide you Zoom services. This includes technical and operational support and service improvement. For example, we collect information such as a user’s IP address and OS and device details to deliver the best possible Zoom experience to you regardless of how and from where you join.  

• We do not use data we obtain from your use of our services, including your meetings, for any advertising. We do use data we obtain from you when you visit our marketing websites, such as zoom.us and zoom.com. You have control over your own cookie settings when visiting our marketing websites.

• We are particularly focused on protecting the privacy of K-12 users. Both Zoom’s Privacy Policy (attached) and Zoom’s K-12 Schools & Districts Privacy Policy are designed to reflect our compliance with the requirements of the Children’s Online Privacy Protection Act (COPPA), the Federal Education Rights and Privacy Act (FERPA), the California Consumer Privacy Act (CCPA), and other applicable laws

Zooms use of Cookies:

When you log in to your Zoom account, Zoom will ask you to accept its use of "cookies".

For the most part, Zoom utilizes "cookies" that collect information about you, such as your log-in details, to enhance the functionality of its site.  However, in addition to the cookies that Zoom uses to help with the functionality of its services and user experience, it also uses "advertising cookies".   Advertising cookies are used by advertising companies to serve ads that are relevant to your interests.

We recommend that you "opt out" of Zoom's use of such advertising cookies, which collect information about you and your use of Zoom's site for advertising purposes.   To opt out of advertising cookies, click on the  "more info" option when you sign in to your Zoom account and are prompted to accept Zoom's cookies.   When you click on "more info", you can then click on "cookie settings", which will  take you to a menu that allows you to select which cookies you permit Zoom to use: Required Cookies/CCPA Opt Out; Functional Cookies; and Advertising Cookies.  You can opt out of Advertising cookies by unselecting that option.

Despite these protections, users should use common sense and avoid sharing more information when necessary when using Zoom, especially when discussing confidential matters.

Additionally, as a user of Zoom, if you give Zoom access to any files or programs you need to manage cookies through your browser settings in the way you do with other applications.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES  

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

OPTIONS REGARDING YOUR INFORMATION

Emails and Communications

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

●      Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Intercultural Roots

hello@interculturalroots.org

+44 7753 611768