LAST UPDATED AND EFFECTIVE AS OF: September 25, 2020
Your privacy is very important to us. While maintaining www.nongmoproject.org, www.livingnongmo.org, and The Non-GMO Project Application (for Your mobile device) (individually and collectively referred to as, the “Websites”), The Non-GMO Project (the “Project”) follows a few key principles:
(A) We are thoughtful about the personal information we ask You to provide and the personal information that we collect about You.
(B) We store personal information for only as long as we have a reason to keep it.
(C) We aim to make it as simple as possible for You to decide and control which personal information You submit to via the Websites is shared publicly (or kept private), indexed by search engines, and/or permanently deleted.
(D) We aim for full transparency on how we gather, use, and share Your personal information.
You can browse parts of the Websites without telling us who You are or revealing any personal information about Yourself. Once You give us Your personal information, You are no longer anonymous. If You choose to provide us with personal information, You consent to the transfer and storage of that information to our servers located in the United States.
3. Legal Basis. The Project has various legal bases for processing information about You, which may include the following: (a) to fulfill the Project’s commitments to You under the TOU Agreement or other agreements with You, or to administer Your account (e.g., to enable You to access the Websites); (b) to comply with a legal requirement or obligation (e.g., to make a mandatory disclosure to law enforcement); (c) to protect Your or another person’s vital interests; (d) for the Project’s legitimate interests (e.g., to manage our relationship or communication with You, or to improve the Websites and any of the Project’s services); and/or (e) You have given Your consent (e.g., to communicate with You about services or provide You with marketing information), which may subsequently be withdrawn at any time by contacting our Chief Operating Officer at email@example.com, without affecting the lawfulness of any consented-to processing before the withdrawal of Your consent).
4. We May Collect Any of the Following Information:
A. PERSONAL INFORMATION. When You sign up for or use the Websites, You may voluntarily share, and we may collect, certain personal information used to identify You, including, but not limited to, Your legal name, age, civil status, occupation; Your contact information, including email address and/or telephone number; Your demographic information, such as postal code, and residential and commercial addresses; and Your preferences and interests. You can also choose to share Your precise location using your device settings or through photos. We may also collect information posted in any comments or discussions You Post in any Q & A, blog, feedback Posting, or other correspondence site on the Website, or any comments You provide during a dispute resolution procedure.
B. NON-PERSONAL INFORMATION. We may collect non-personal information, such as Your browser type, Your ISP or operating system, the URL of the previous website You visited, and Your IP address, none of which can be easily used to identify You.
C. COOKIES INFORMATION. When You visit the Websites, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to Your computer that identifies Your browser. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify Your browser setting to decline cookies if You prefer. Cookies allow web applications to respond to You as an individual, tailoring its operations to Your needs, likes and dislikes by gathering and remembering information about Your preferences. If You disable cookies You may be prevented from taking full advantage of the Websites because they may not function properly if the ability to accept cookies is disabled.
D. AGGREGATED INFORMATION. Please note that any of the information we collect about You may be aggregated; Your personal information, however, will not identifiable.
E. PERSONAL INFORMATION FROM OTHER SOURCES. In addition to personal information You may submit via the Websites, we collect personal information from other sources, where permitted by law, as follows: (i) through interactive applications (e.g., mobile devices, third-party services, and embedded audio and video players); (ii) from co-branded services and third-party websites (e.g., Facebook, Google, Wufoo Forms, Gravity Forms); and (iii) and from commercially available sources (e.g., data aggregators and public databases). The following lists the information that we may collect from such other sources: (a) Your name, postal address, and telephone number; (b) Your demographic data, such as Your age, gender, and income level; (c) if You access third party services (e.g., Facebook or Google) through the Websites, or if you access the Websites via a third-party service provider, Your username and password for those services and other information available about or collected from You on those services; (d) Your interests and purchase behavior; (e) publicly-observed data, such as activities on blogs, videos, and other online postings; and (f) other navigation data, such as websites visited and advertisements viewed or clicked on.
5. What Non-GMO Project May Do With the Information We Gather:
A. HOW PERSONAL INFORMATION MAY BE USED. We may use the personal information You provide for any of the following reasons:
1. To enable You to participate in any interactive services, including, without limitation, any questionnaires, surveys, polls, contests, message boards, giveaways, quizzes, or other educational challenges;
2. Internal record keeping;
3. To improve the Websites, our services, and to provide the services and customer support that You want;
4. To periodically send promotional emails to the email address You provide regarding new services or other information that we think You may find interesting;
5. To contact You, via email, telephone, facsimile or mail, or for market research purposes, including, but not limited to, the customization of the Websites according to Your interests; and
6. We may use Your demographics information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of our services to appropriate target audiences.
7. To fulfill Your requests for products, services, and information, including to send You electronic newsletters and complete transactions that You have requested;
8. To analyze the use of the Websites and information about Website visitors, understand and improve our service offerings and, in accordance with our sharing policies, discussed below, to produce or disclose anonymous or aggregated data and statistics that might help third parties develop their own products and service offerings;
9. For any other purposes disclosed to You at the time we collect Your information or pursuant to Your consent.
B. HOW NON-PERSONAL AND COOKIES INFORMATION MAY BE USED. We may track user traffic patterns throughout the Websites and use traffic log cookies to identify which pages are being used. This would help us analyze data about webpage traffic and improve our Websites in order to tailor it to customer needs. We would only use this information for statistical analysis purposes and then the data would be removed from the system. Overall, cookies help us provide You with better Websites, by enabling us to monitor which pages You find useful and which You do not. A cookie does not give us access to Your computer or any information about You, other than the data You choose to share with us.
C. OTHER USES. We may also use any of the above-referenced information that we gather to (a) resolve disputes, (b) troubleshoot problems, (c) prevent potentially prohibited or illegal activities, (d) enforce the TOU Agreement, or (e) customize, measure, and improve the Website’s content and design.
You should also be aware that we may also engage a third party to provide some of the services associated with the blogs, message boards, and similar functions. This third party will collect and host the information that you submit to the Websites, but will not use any of this information for purposes other than providing such services. Further, public information may be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what You would like to share.
For the avoidance of doubt, the Project is not responsible for maintaining as confidential any personal or other data that You Post on our Websites.
6. Controlling, Accessing, and Deleting Your Personal Information. You may choose to restrict the collection or use of Your personal information in the following ways:
Once You Post any Content onto the Websites, You may not be able to change or remove it. Typically, we will not manually alter Your personal information because it is very difficult to verify Your identity remotely. Nonetheless, upon Your request, we will close Your account and remove Your personal information from view as soon as reasonably possible. We retain information from closed accounts in accordance with applicable law, which may include the following reasons: to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any user, enforce the TOU Agreement, or take any other actions otherwise permitted by law that we deem necessary, in our sole and absolute discretion.
More specifically, please note Your rights and certain terms in connection with Your access to and our retention of Your personal information, as follows:
A. YOUR RIGHTS TO CONTROL YOUR PERSONAL INFORMATION. You may decline to share certain personal information with us, in which case we may not be able to provide some of the features and functionality of the Websites. In addition, You have the right to (a) access Your personal information by requesting that a copy of it be sent to You or a third party; (b) correct or delete Your personal information; (c) object to our use of Your personal information; (d) request that we limit our use and processing of Your personal information; and (e) request portability of Your personal information. In order to access, correct, or delete Your personal information, or to contact us about one of the other rights, please email firstname.lastname@example.org.
B. ACCESS TO YOUR PERSONAL INFORMATION. To request access to Your personal information, please email the Project at email@example.com. We will use commercially reasonable efforts to provide the information free of charge, within 30 days of Your access request, except in the event that the request is unfounded, excessive, or repetitive, in which case we reserve the right to charge a reasonable administrative fee or refuse such request. We provide this access so that you may review, make corrections, or request deletion of Your personal information. If we cannot fulfill Your request within 30 days, we will inform You when we will be able to provide such access. If for some reason access is denied, we will provide an explanation as to why access is denied.
C. DELETION OF YOUR PERSONAL INFORMATION. Please note that requesting deletion of Your personal information is total and irreversible, subject to the retention of personal information for specific and limited reasons, as noted above in the first paragraph of this Section 6. If You re-join the Websites, by voluntarily providing Your personal information, You will appear to us as a completely new data subject. This does not affect Your other rights in any way. To request deletion of Your personal information, please contact firstname.lastname@example.org, using the email address we have on file for You, or otherwise proving Your identity.
E. CHOICES. In addition to the above, You have the following choices in connection with Your information:
(i) Limit the Information that You Provide: If You have an account created with respect to any services offered through the Website(s), You can choose not to provide any optional account information, profile information, and any transaction and billing information. Please note that if you do not provide this information, certain features of our Website(s) may not be accessible.
(ii) Limit Access to Information On Your Mobile Device: Your mobile device operating system should provide You with the ability to discontinue our ability to collect stored or location information via any of our mobile apps. If You choose to discontinue this ability, You may not be able to use certain features.
(iii) Link or Unlink Your Website Account(s) from Other Services (e.g., Facebook, Google).
(iv) Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If You opt out of promotional messages, we may still send You other messages, like those about Your account and legal notices.
(v) Set Your Browser to Reject Cookies: At this time, the Project does not respond to “do not track” signals across all of our Websites. However, you can usually choose to set your browser to remove or reject browser cookies before using the Websites, with the drawback that certain features of the Websites may not function properly without the aid of cookies.
(vi) Close Your Account at Any Time: If You no longer want to use the Websites, You may close any account You have opened. Please keep in mind that we may continue to retain Your information after closing Your account, as described above, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
7. Children. This Website is not directed to persons under 13. If you become aware that Your child has provided us with personal information without your consent, please contact us at email@example.com. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly request, collect, or maintain personally identifiable information from anyone under the age of 13 without verified parental consent. If we learn that personally identifiable information of anyone under the age of 13 has been collected on the Website without verified parental consent, then we will promptly take the appropriate steps to remove this information.
8. Security and Disclosure of Personal Information. We are committed to ensuring that Your information is secure. When You submit sensitive information via the Websites, Your information is protected both online and offline. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. Your information is stored on our servers located in the United States. We treat data as an asset that must be protected and use various tools (e.g., encryption, passwords, physical security, etc.) to protect Your personal information against unauthorized access and disclosure. However, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse Your personal information that they collect from the Website. Although we work very hard to protect Your privacy, we do not promise and cannot guarantee, and thus You should not expect, that Your personal information or private communications will always remain private.
We only give access to Your personal information to those employees or third-party service providers (set forth in subsection B below) who need the information to perform a specific job.
A. INFORMATION DISCLOSED TO UNAFFILIATED THIRD PARTIES. We may disclose Your personal information to prevent an emergency, to protect or enforce our rights, to protect or enforce the rights of a third party, or as required by law (e.g., to comply with a subpoena or court order). Specifically, if You Post any Content we may disclose Your information to a third party that alleges that You have infringed their intellectual property rights in any Content.
B. INFORMATION DISCLOSED TO THIRD-PARTY SERVICE PROVIDERS. We may contract with various third parties for the provision and maintenance of the Websites and our business operations. We will use commercially reasonable efforts to prevent such third parties from disclosing Your personal information, except for the purpose of providing the specific services. We, however, cannot guarantee that such third parties will not disclose Your personal information. Currently, the Project works with various third-party Technical Administrators to assist the Project with operating the Product Verification Program and may share Your information with such Technical Administrators, which include the following: FoodChain ID, Where Food Comes From Inc., SCS Global Services, and NSF International.
C. INFORMATION DISCLOSED TO CORPORATE AFFILIATES. We may share Your personal information with our affiliates to help detect and prevent potentially illegal acts and to provide joint services. Our affiliates will market only to users who request such services.
D. INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT OFFICIALS. We may share Your personal information, such as Your name, city, state, telephone number, email address, user ID history, bidding and listing history, and fraud complaints, with law enforcement or other government officials in response to a verified request in connection with a criminal investigation or any alleged illegal activity.
E. INFORMATION DISCLOSED AT YOUR REQUEST. We may share Your personal information with third parties to whom You explicitly ask us to send Your information.
F. AGGREGATED OR DE-IDENTIFIED INFORMATION. We may share information that has been aggregated or anonymized so that the information could not reasonably be used to identify You. For example, we may publish aggregate statistics about the use of the Websites or our services or use such information to help us develop content and services we hope will interest You or to help third parties develop their own products and service offerings including targeted marketing.
G. CONTESTS OR PROMOTIONS. When You choose to enter a contest or other promotion, in accordance with the terms and conditions of such contest or promotion, Your information may be disclosed to third parties who help design, administer and implement the contest or promotion, including in connection with winner selection, prize fulfillment and aggregated data analysis. Your information also may be disclosed as required by law, such as on a winners list. Further, by entering a contest or other promotion, You are agreeing to the official rules that govern that contest or promotion, including allowing the Project or our sponsors to use Your name, voice, and likeness in advertising and marketing associated with the contest or promotion, in accordance with applicable law. All terms applicable to the particular promotion will be made available to You at the time You enter the contest or promotion.
I. SOCIAL NETWORKS. Information collected about Your interactions with audio and video content may be shared with third parties, including social networking services, such as Facebook, Google, Twitter, and/or Instagram. For example, You can use third-party social networking services, such as Facebook, Google, Twitter, or Instagram to share information about Your experience with the Websites or any Project services, contests, or products with Your friends and followers on those social networks. These social networking services may be able to collect information about You, including about Your activities in connection with the Project or the Websites, and they also may notify Your friends, both on the Websites and on their social network services, that You are a Website user or about Your use of the Website, in accordance with applicable law and their own privacy policies.
By using the Website in connection with a third-party social networking service, You consent to share information about You, including Content that You have seen or Posted on the Websites, with Your friends and followers on those networking services. You can limit how third-party social networking services share Your information by visiting Your social networking services’ websites and updating Your privacy settings.
In addition, the Project may request Your permission to (a) access and collect information available from Your social networking account; or (b) post information to Your friends on your behalf. If You connect Your social networking service with the Website or Your account, You authorize the Project to access certain information about You from Your social networking service to provide content and services, including to help the Project tailor its communications to You and to develop online materials and services across the Websites. Any information the Project may access from your social networking services is governed by the privacy policies and settings of those third-party services.
9. Links to Other Websites. The Website may contain links to other websites of interest. However, once You have used these links to leave our site, You should note that we do not have any control over the other website to which You are directed. We cannot, therefore, be responsible for the protection and privacy of any information that You provide while visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question
10. Account Protection. If You have an account with a password, Your password is the key to Your account. If and when you create Your password You should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclose Your password to anyone. If You share Your password or Your personal information with others, You are solely responsible for all actions taken via Your account. If You lose control of Your password, You may lose substantial control over Your personal information and be subject to legally binding actions taken on Your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY THE PROJECT TO CHANGE YOUR PASSWORD.
You can ask us for more information about the steps we take to protect Your personal information when transferring it from outside of the United States.
13. Website Users from California. Residents of the State of California may request a list of all third parties to which the Project has disclosed certain information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and would like such a list, please contact the Project by emailing firstname.lastname@example.org. If You are a California resident under the age of 18, and a registered user of any Website where this policy is posted, You may request removal of Content or information You have publicly Posted. Please be aware that such a request does not ensure complete or comprehensive removal of the Content or information you Posted and there may be circumstances in which the law does not require or allow removal.
You must put the statement “Your California Privacy Rights” in the subject field of Your request and include the URL of the Website with respect to which you are requesting the information. You must also include Your full name, street address, city, state, and zip code. We will not accept requests via telephone, postal mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.