SEED’s Privacy Policy
 

Last updated: February 2021
 

Thank you for choosing to be part of our community at SEED: Strategies for Ethical and Environmental Development, Inc. (“SEED,” “Organization,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us by emailing us at info@ethicalstrategies.org
 

When you visit our websites, including www.ethicalstrategies.org and www.seedundercoverinvestigations.com, and use our services, you trust us with your personal information. We take your privacy very seriously. This policy describes the types of information we may collect from you or that you may provide when you visit our website(s) (“Sites”) and/or any related services, marketing, or events and details our practices for collecting, using, maintaining, protecting, and disclosing that information, and your rights in relation to our collection and use of your information. If there are any terms in this policy that you do not agree with, please discontinue use of our Sites and services.
 

This policy applies to information we collect:
 

  • on our Sites; and

  • in email, text, and other electronic messages between you and SEED.

 

TABLE OF CONTENTS

  1. What Information Do We Collect?

  2.  How Do We Use Your Information?

  3. Will Your Information Be Shared With Anyone?

  4. Do We Use Cookies And Other Tracking Technologies?

  5. How Do We Handle Your Social Logins?

  6. What Is Our Stance On Third-party Websites?

  7. How Long Do We Keep Your Information?

  8. How Do We Keep Your Information Safe?

  9. Do We Collect Information From Minors?

  10. What Are Your Privacy Rights?

  11. Do California Residents Have Specific Privacy Rights?

  12. Do EU Residents Have Specific Privacy Rights?

  13. Do We Make Updates To This Policy?

  14. How Can You Contact Us About This Policy?

  15. How Can You Review, Update, Or Delete The Data We Collect From You?

 

  1. What Information Do We Collect?
     

Personal Information You Disclose To Us
 

We collect personal information you provide to us such as your name, address, contact information, payment information, and social media login data.
 

We collect personal information you voluntarily provide to us when registering at our Sites, expressing an interest in obtaining information about us or our work, when participating in activities on our Sites (such as posting messages in online forums) or otherwise contacting us.
 

The personal information that we collect depends on the context of your interactions with us and our Sites, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Name and Contact Data. We may collect your name, email address, postal address, phone number, and other similar contact data.
     

  • Credentials. We may collect usernames, passwords, password hints, and similar security information used for authentication and account access, if applicable.
     

  • Payment Data. We may collect data necessary to process your payment if you make a donation, such as your payment instrument number (for example, your credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
     

  • Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter, or other social media accounts. If you choose to register in this way, we will collect the Information described in the applicable section below.
     

  • Technical & Usage Data. We may use cookies which collect data including your internet protocol (IP) address, device IDs, login data, browser type and version, time zone setting and location, browser plug-in types, versions, operating system and platform, and other technology on the devices you use to access the Sites and information about how you use our website, products and services. See the applicable section below for further information.
     

  • Marketing Data. We may collect additional information, including donations made by you, your feedback, and your preferences in receiving marketing or communications from us and our affiliates, if applicable.
     

Information Collected From Other Sources
 

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and/or other outside sources.
 

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads; and search results and links, including paid listings (such as sponsored links).
 

2. How Do We Use Your Information?
 

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
 

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.


We use the information we collect or receive:
 

  • To Facilitate Account Creation And Logon Process With Your Consent. If you choose to link your account with us to a third-party account (such as a Facebook account), we use the information collected from the third party to facilitate the account creation process. See the applicable section below for further information.
     

  • To Send You Marketing And Promotional Communications For Business Purposes and/or With Your Consent. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS” below). Please note that in some cases we or our third-party marketing partners may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites. See the applicable section below for further information.

 

  • To Send Administrative Information To You For Business Purposes and/or Legal Reasons. We may use your personal information to send you program and new feature information and/or information about changes to our terms, conditions, and policies.
     

  • Request Feedback For Our Business Purposes and/or With Your Consent. We may use your information to request feedback and to contact you about your use of our Sites.
     

  • To Enforce Our Terms, Conditions And Policies For Business Purposes and/or Legal Reasons. We may use your personal information to enforce our terms, conditions, and policies

 

 

​3. Will Your Information Be Shared With Anyone?
 

In Short: We only share information with your Consent, to comply with laws, to protect your rights, or to fulfill business obligations. Unless described in this policy, we do not sell, rent or otherwise disclose personal information collected by our site to third parties in the ordinary course of business.
 

We only share and disclose your information in the following situations:
 

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental or regulatory requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
     

  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
     

  • Internal Business Operations. We may disclose your information to our subsidiaries or affiliates.
     

  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work, provided that such vendors agree to keep any data confidential and secure. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
     

  • Business Transfers. We may share or transfer your information to a successor in connection with, or during negotiations of, a merger, reorganization, dissolution, or other transfer of some or all of SEED’s assets, whether as a going concern or as part of bankruptcy or similar proceeding in which personal information held by SEED about our Site users is among the assets transferred.
     

  • With your Consent. We may disclose your personal information for any other purpose with your Consent.
     

 

4. Do We Use Cookies And Other Tracking Technologies?
 

In Short: We may use cookies and other tracking technologies to collect and store your information.
 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
 

Please note that some content or applications on the Sites may be served by third-party marketing partners. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Sites. The information they collect may be associated with your personal information or they may collect information about your online activities over time and across different websites and online services. They may use this information to provide you with interest-based advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. These third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.
 

5. How Do We Handle Your Social Logins?

In Short: If you are given the option and choose to register or log in to our websites using a social media account, we may have access to certain information about you.
 

Our Sites offer you the ability to register and login using your third-party social media account details (like Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The Information may vary depending on the social media provider, but will often include your name, e-mail address, friends list, profile picture, and other public information.
 

We may use the Information only for the purposes that are described in this policy or that are otherwise made clear to you on our Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by third-party social media providers. 
 

6. What Is Our Stance On Third-party Websites?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Sites.
 

Our Sites may contain advertisements from third parties that are not affiliated with SEED and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from our Sites. 

 


7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.
 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet is completely secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. 

 

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

Our Sites are not intended for children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us by using the contact information provided in the section below headed “How Can You Contact Us About This Policy?”

10. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.
 

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find the appropriate contact details at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm


Account Information
 

If you would at any time like to review or change the information in your account or terminate your account, you can:
 

  • Contact us using the contact information provided in the section below headed “How Can You Contact Us About This Policy?”; or
     

  • Log into your account settings and update your user account, if applicable.
     

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.


Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our policies, and/or comply with legal requirements.


Cookies and similar technologies: most Web browsers are set to accept cookies by default. If you prefer, you may choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Sites, please visit http://www.aboutads.info/choices/.


Opting out of email marketing: you may unsubscribe from our email lists at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the email list(s) – however, we may still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
 

  • Note your preferences when you register an account with our Sites;
     

  • Access your account settings and update preferences; or 
     

  • Contact us using the contact information provided in the section below headed “How Can You Contact Us About This Policy?”.

 

 

11. Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. However, please note that we are providing this information voluntarily. The law that requires additional notice – the California Consumer Privacy Act of 2018 (“CCPA”) – does not apply to non-profit entities like SEED.
 

If you are under 18 years of age, reside in California, and have a registered account with our Sites, we offer you the ability to make the requests listed below. However, in certain circumstances, we may decline your request. If we deny your request, we will communicate our decision to you. You will not be penalized for making a request.
 

  • Information. You can request information about how we have collected, used, and shared your personal information during the past 12 months.
     

  • Access. You can request a copy of the personal information that we maintain about you
     

  • Deletion. You can request removal of unwanted data that you publicly post on the Sites, if applicable. We will make sure the data is not publicly displayed on our Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
     

  • List of Third-Party Marketers.  California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain, once a year and free of charge, information about categories of personal information (if any) we have 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 along with a statement that you reside in California and the email address associated with your account to us using the contact information provided below. Please note that California residents can empower an "authorized agent" to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

12. Do EEA Residents Have Specific Privacy Rights?

 

In Short: Yes, if you are a resident in the European Economic Area (“EEA”), you have certain additional rights and protections with respect to the process and transfer of your personal data.
 

Under certain circumstances, you may have the following additional rights under data protection laws in relation to your personal data:
 

  • The Right To Access. You have the right to request that we provide you with copies of your personal data.
     

  • The Right To Rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
     

  • The Right To Erasure. You have the right to request that we erase your personal data, under certain conditions.
     

  • The Right To Restrict Processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
     

  • The Right To Object To Processing. You have the right to object to our processing of your personal data, under certain conditions.
     

  • The Right To Data Portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

 

If you wish to exercise any of the rights set out above, please contact us by using the contact information provided in the section below headed “How Can You Contact Us About This Policy?”

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than 30 days, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

13. Do We Make Updates To This Policy?

In Short: Yes, we may update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Last Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this privacy policy to check for any changes. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information. 

14. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, or any other SEED policy, you may email us at info@ethicalstrategies.org or by mail to:
 

SEED: Strategies for Ethical and Environmental Development, Inc.
1421 Orleans Road, PMB #311 

East Harwich, MA 02645 

United States

 

 

15. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the laws of some states and countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request using the information above. We will respond to your request within 30 days.