Privacy Policy


Updated November 2017

 

1. Preamble

 

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, processing, transferring and disclosure of “personal information” by Smoove Gang Ent. (“SG” or “Smoove Gang”), and also contains an Express Consent that applies to those who use our Websites and Services (as defined below). This Privacy Policy is incorporated into and made part of Smoove Gang Master Terms of Use (“Master Terms”).

 

Unless otherwise noted on a particular website or service hosted by Smoove Gang, this Privacy Policy applies to your use of all websites that Smoove Gang operates, together with all other subdomains thereof (collectively, the “Websites”). This Privacy Policy also applies to all products, information, and services provided through the Websites. Furthermore, this Privacy Policy does not apply to any of the websites operated by affiliates or chapters of Smoove Gang unless expressly provided on those websites or any subdomains of the Websites.

 

In addition, supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to a particular Service. All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that particular Service.

 

This Privacy Policy also explains our commitment to you with respect to our use, processing, transfer and disclosure of non personal browsing and site usage data that Smoove Gang collects as the provider of the Services. “Non personal browsing and site usage data” refers to information that SG collects indirectly and automatically about your activities while visiting the Websites and using the Services through tools such as Google Analytics. The type of information that we collect focuses on general information such as general location such as country or city where you are located (not intentionally fine-grained location information), pages visited, heat-map of visitors’ activity on the site, information about the browser you are using, etc. In addition, whenever you log into a Website or use the Services, our servers (which, again, may be hosted by a third party service provider) keep a plain text log of the websites you visit and when you visit them. SG does not deliberately track people over the Internet. See section 11, below for more information about this.

 

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address or information from which a person could deduce your identity.

 

By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.

 

2. Our Principles

 

Smoove Gang is committed to handling responsibly the personal information and data we collect and process about you through our Services, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy consistent with the following principles (the “Principles”):

 

Privacy policies including provisions regarding data collection, processing and use, should be human readable, comprehensive, and easy to locate;

 

Only the minimum amount of personal information reasonably necessary to provide you with services should be processed, collected and maintained, and only for so long as reasonably needed or required, consistent with the principles of proportionality; and

 

Personal information you provide through our Services, or that we gather as a result of your use of our Services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required.

 

3. Personal Information SG Collects

 

We may collect and process personal information through our Services, including without limitation:

 

– when you provide us with your personal information such as by sending an email to us or signing up to receive updates from Smoove Gang;

– when you subscribe to one of our email discussion lists;

– when you donate money to us or purchase merchandise;

– when you create an online account;

– when you provide personal information in connection with your participation in any of our Websites or our Services.

 

4. What SG Does with Personal Information

 

Emails and Newsletters . We use the personal information you provide to us when you send us emails or sign up to receive updates from Smoove Gang in order to respond to your request – for example, to reply to your email or to send you communications about Smoove Gang news and campaigns.

 

When you subscribe to updates from us, your email address is sent to and stored in a Customer Relationship Management (CRM) database (such as MailChimp, or CiviCRM) hosted on servers that can only be accessed by Smoove Gang staff and contractors. SG may change CRM system(s) from time to time. Personal information submitted as part of our email discussion lists is used for the purpose of managing the discussion lists. 

 

Events and Payments: If you sign up for an event hosted or supported by Smoove Gang, we may share your personal information with vendors and third party contractors solely for the purpose of organizing and running the event. Additionally, if you make any payments for any Products or Services, you affirmatively consent and agree that SG may use and process your information in connection with the use and processing of your attendance with any such third party payment processors for purposes of processing your payment. Your information is subject to the privacy policies of such third party websites, and you affirmatively consent to the transfer of your information to those websites and service providers. SG is not be responsible for their handling, processing and use of your information.

 

Donations . When you donate money, goods or services to us, purchase merchandise via our Websites, or pay for attendance at an event, your personal information will be handled depending on which option you choose.

 

If you make a purchase from our online store, your personal information will be used for the purpose of sending you the items you purchased. If you sign up to receive updates from Smoove Gang when you check out from our online store, we will use your personal information to send you communications about Smoove Gang news and campaigns.

 

You may donate money to Smoove Gang directly or through a variety of on-line payment sites. When you use any of those websites and services to donate to SG, your personal information is sent to, processed by and stored by those websites in accordance with their respective privacy policies and terms of use. You should read and understand the privacy policy and terms of use of any website you use to donate to Smoove Gang. When you donate to Smoove Gang directly, we use your personal information to process your donation. If you sign up to receive updates from Smoove Gang when you provide your donation, we will use your personal information to send you communications about Smoove Gang news and campaigns.

 

5. SG Website

 

If you create an online account with us and provide personal information, we use that personal information to establish and maintain your accounts, provide you with the features we provide for account holders, to act as your service provider, and for the purpose of contacting you about upcoming news and events relevant to Smoove Gang.

 

If you are given a public profile page where you can voluntarily post personal information for public viewing, the information that you submit on your public profile page, including but not limited to information you provide in the text fields and any photograph or image of yourself you choose to upload, is posted by you at your discretion (although subject to our Master Terms of Use). You should not post photos or images of other persons without their express consent. The information you publish on your public profile page, including your personal information, may be used by anyone who views that information for any lawful purpose. SG may use the personal and non personal browsing and site usage date, provided in your public profile, to promote the mission of Smoove Gang.

 

6. Disclosures of Personal Information

 

In general, it is not Smoove Gang’ practice to disclose personal information to third parties other than as made available on the Services. Except as otherwise set forth herein or for providing you with attribution using your account name or nickname (as you have elected), we may share your personal information in the following instances:

 

First, Smoove Gang may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services, or to organize and run an event you signed up to attend.

 

Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms and this Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) address legitimate interests pursued by Smoove Gang or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child) and ensure our compliance with applicable laws.

 

For the purposes listed in section 3 above, Smoove Gang may transfer your personal information to Smoove Gang affiliates, members, chapters, and third parties that provide products or services to Smoove Gang.

 

When personal information is directly transferred to an affiliate, member, Chapter or a third party provider located in a country including those listed above, that may not provide a level of protection equivalent to the laws in your jurisdiction, Smoove Gang will exercise appropriate due diligence in the selection of such recipients, and require that these recipients maintain adequate technical and organizational security measures to safeguard the personal information and process the personal information only as instructed by Smoove Gang and for no other purposes. 

 

7. Security of Personal Information Collected via the Services

 

Smoove Gang has implemented reasonable physical, technical, and organizational security measures for personal information that Smoove Gang processes, transfers, stores and controls against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

 

Our login and account systems have security risks in addition to those described above. Among other things, they are vulnerable to DNS attacks, and using any login service may increase the risk of phishing.

 

8. Information from Cookies and Similar Technologies

 

We and our service providers (for example, Google Analytics as described in section 1 above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities. The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

 

9. Non Personal Browsing and Site Usage Information We Process and Collect

 

When you use the Services, our servers (which may be hosted by a third party service provider) may process and collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and using our Services, and information about the country you are located in and the browser you are using. In addition, we use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about the use of the Websites and Services, and to report trends, without identifying individual visitors (this is all “non personal browsing and site usage information” for purposes of this Privacy Policy and as described in section 1, above). The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. Whenever you use an account on our Websites, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them. We may share the non personal browsing information we collect with our third party service providers in connection with the services they provide.

 

10. No Linking

 

We do not intentionally link browsing information or information from our login server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. SG may use a third party analytics provider (for example, Google Analytics as discussed in section 1 above) to help us collect and analyze non personal browsing and site usage information through operation of our Services for those same purposes.

 

In connection with your use of the Services, you may tag content, create lists of favorite content, and do other things to personalize your experience. You should not, however, tag other persons or post photographs or other images or likenesses without that other person’s express consent. This information will be retained by Smoove Gang in connection with the relevant Service.

 

11. No Selling or Sharing

 

Except in the unique situations identified in this Privacy Policy, Smoove Gang does not sell or otherwise voluntarily provide the non personal browsing information we collect and process about you or your website usage to third parties.

 

 

12. Data Retention

 

SG generally discards non personal browsing information from our Services and Websites once we have used the information for the limited purposes noted above under “No Linking” and described elsewhere in this Privacy Policy. Nevertheless, we may, but are not obligated to, retain certain data in connection with routine information technology backups and for archival purposes.

 

13. Notice

 

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles.

 

14. Reorganization or Spin-Offs

 

Smoove Gang may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, Smoove Gang will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles and with all applicable laws.

 

15. Children

 

The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms specifically prohibit anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to SG through the Services represents that they are 13 years of age or older.

 

16. Third-Party Sites

 

The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

 

17. Special Note to International Users

 

If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. The Services are hosted in the United States and the United Kingdom. Please note that your personal information may be located on servers in the United States and/or the United Kingdom. By providing your personal information to access and use our Services, you expressly consent to the use of your personal information for the uses identified above in accordance with the Privacy Policy.

 

18. Accuracy of Personal Information Collected

 

Smoove Gang intends to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to carry out the purposes described above, or as required by law. If changes need to be made to your personal information, please notify us (as identified below, see the “Questions” section) right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in personal information, we will promptly make changes as appropriate. You also have the option to update some of your personal information yourself via your Smoove Gang account or profile if you have one.

 

19. Access to Personal Information

 

Along with all other rights granted to you under applicable laws, you may at any time request to be informed of personal information that Smoove Gang holds. If you wish to access such personal information, you should apply in writing to Smoove Gang (as identified below, see the “Questions” section). You are generally entitled to access personal information that Smoove Gang holds and to have inaccurate data corrected or removed to the extent SG still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information.

 

20. Changes and Updates to this Privacy Policy

 

We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services, and will revise the Effective Date above. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.

 

 

21. Questions?

 

If you have questions about this Privacy Policy, please contact us by email at [email protected]

 

* This Privacy Policy has been adopted from Creative Commons under Creative Commons CC0 Public Domain Dedication.