Adoptions With Love Privacy Policy

Adoptions With Love, Inc., a Massachusetts non-profit corporation -based (hereinafter “AWL”) processes Personal Data (as defined below) in the course of its business, including the Personal Data of people browsing the AWL’s website (the “Site”). The purpose of this “Privacy Policy” is to inform all individuals from whom Personal Data is collected by AWL (“You” or “Your”) how AWL collects and uses such Personal Data and how You can control its use.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy sets forth the principles and guidelines governing the protection of Your Personal Data including the Personal Data collected on or through the Site. AWL collects Personal Data either online (including via email) or offline and this Privacy Policy is applicable regardless of the means of collection or processing. Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person. Non-Personal Data means any information that does not result in the identification of a person. For visitors and users of the Site: The Site is subject to Terms of Use that can be found the Site and are incorporated into this Privacy Policy. Your use of the Site and any Personal Data You provide on the Site are subject to the terms of this Privacy Policy and the applicable Terms of Use.

2. DATA COLLECTED

a. Visitors Visitors are individuals who visit the Site without registering themselves. Their Personal Data likely includes: IP and/or MAC address Cookies (as described in section 10); and any other Personal Data as may be relevant for the purposes listed below. b. Users Personal Data collected (including from those who visit Site and enter information) for the purposes listed below likely includes: title; first and last name; postal address; email address; telephone number(s); login and password; university, degree and courses taken; IP and/or MAC address; Cookies (as described in section 10); and any other Personal Data as may be relevant for the purposes listed below. In all cases, however, the Personal Data gathered is limited to data necessary for the purposes described in Article 4 below. For visitors and users of the Site: in order to use certain functions and features of the Site, AWL requires that You provide certain Personal Data when visiting or using the Site. You are free to decide whether or not to provide all or part of Your Personal Data. However, if You choose not to provide all or part of this Personal Data, the purposes as described in Article 4 hereafter might not be achieved or not properly achieved, some areas and functions of the Site may not function properly and/or You may be refused access to certain pages on the Site.

3. PROTECTION OF PERSONAL DATA CONCERNING CHILDREN

Children AWL services are not designed to be marketed to children who are considered as minor under the applicable data protection law and AWL does not knowingly collect or store Personal Data from children under such age. If parents or guardians become aware that their child has provided AWL with Personal Data without their consent, they can ask AWL to remove such Personal Data by sending an email to info@awlonline.org If AWL becomes aware that it has collected Personal Data from a child below the age of consent under local data protection laws without consent from a parent or guardian, AWL will take steps to seek the parent’s or guardian’s consent for that processing or to remove such Personal Data and terminate the child’s account.

4. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Whether You are a visitor or a user, AWL collects Your Personal Data for the following legal grounds and for the following purposes: – Processing activities based on Your consent: To improve Your user experience; To recognize that You have given a Personal Data so You do not need to do it for every web page requested; – Processing activities based on AWL’s legitimate interest: To enable AWL to manage surveys. In addition, when You are a user, AWL collects Your Personal Data on the following legal grounds and for the following purposes: – Processing activities based on Your prior consent: To enable You to request and receive information on AWL and AWL services from AWL or a third-party engaged by AWL; To ascertain Your requirements and interests and provide You with the most services; To enable AWL to manage its marketing activities To enable You to register for a seminar, webinar, or event; AWL may provide some strictly necessary personal data such as a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram, or Google) where this information is matched against the social networks own databases in order to display to You more relevant information. – Processing based on AWL’s legitimate interest: To enable AWL to manage its marketing activities for similar goods and products if You are already using AWL products and services; To provide You with a personalized interactive use of the Site; To allow You to open and maintain an account in order to obtain specialized documentation and technical assistance; To access all the features and options offered by the Site; and To enable You to exchange with other users of the Site; Generally, when consent is not required, You cannot opt out of non-marketing related communications that are required for the relevant business relationship. With regard to marketing-related communications (e.g., emails and phone calls), AWL will (i) where legally required, only send You such communications after You have opted in, and (ii) provide You the opportunity to opt out of receiving further marketing-related communications from AWL. When You register for an event organized by AWL, AWL may share Your name, company, and email address with other participants and sponsors of the same event for the purpose of communication and the exchange of ideas. In addition, AWL may ask You for information about Your health for the sole purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Subject to applicable local law, by providing Personal Data such as but not limited to e-mail address, You hereby expressly authorize AWL to use it together with other relevant Personal Data to send You commercial or marketing communications. AWL might also use Your email address for administrative or other non-marketing purposes (for example, to notify You of significant changes to the Site).

5. PERSONAL DATA RETENTION PERIOD AWL

does not store Your Personal Data for more time than necessary. Retention periods may vary depending on the data categories and the processing activities. Where AWL is processing and using Your Personal Data as permitted by law or under Your consent, AWL will store Your Personal Data (i) only as long as required to fulfill the purposes set out above, (ii) where AWL has a legitimate interest in using Your Personal Data, until You object to AWL’s use of Your Personal Data, or (iii) where You gave Your consent, until You withdraw it. However, where AWL is required by applicable law to retain Your Personal Data longer or where Your Personal Data is required to assert or defend against legal claims, AWL will retain Your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

6. RIGHT TO ACCESS, TO RECTIFICATION AND OTHER RIGHTS

AWL will take reasonable steps to ensure that the Personal Data collected is used for the purposes stated in this Privacy Policy and that such Personal Data is correct and up to date. You have a right to access Your Personal Data. In addition, You have a right to request the rectification, completion, update or erasure of Your Personal Data. You have a right to restrict processing. You also have a right to obtain a copy of Your Personal Data stored by AWL. You have a right to object, in relation to specific processing of Your Personal Data. Additionally, You may have a right to data portability. If You have an account, You can exercise Your rights by logging on to Your account. Otherwise, You may exercise Your rights by sending an email to the: info@awlonline.org Depending on the scope of the request, AWL reserves the right to charge a reasonable fee to cover any out-of-pocket costs incurred in connection with such access, modification and deletion of Personal Data. AWL may deny access to Personal Data in limited circumstances, defined by applicable laws and regulations.

7. DATA RECIPIENTS

Where AWL has knowledge that a third-party to which AWL has provided Personal Data for the purposes listed in Article 4 above, is using or disclosing Personal Data contrary to this Privacy Policy or to applicable laws, AWL will take reasonable steps to prevent or stop such use or disclosure. AWL will also disclose Your Personal Data to third-parties if AWL determines that such disclosure is necessary for technical reasons (such as hosting services by a third-party) or to protect AWL’s legal interests (such as in the event of a sale of assets to a third company, or a change of control or a total or partial liquidation of AWL). AWL may also disclose Your Personal Data if required by law or if AWL believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, a subpoena, or other court order) or protect the rights, property, or personal safety of AWL, AWL’s customers, or the public. If allowed by applicable law, AWL may also share Your Personal Data with third-parties in order to offer You targeted marketing or advertising.

8. DATA SECURITY AWL

undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties. AWL maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. As part of those safeguards, AWL employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third-parties. However, while AWL strives to protect Your Personal Data, in light of the inevitable risks of data transmission over the internet, AWL cannot guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond AWL’ reasonable control. Since all Personal Data is confidential, access is limited to employees, contractors and agents of AWL who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations. However, it is important for You to exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and information appearing on Your account. Consequently, You must ensure that You log out of Your session in the event of shared use of a computer.

9. COOKIES

The Site may use cookies or other technologies serving the same or similar purpose (together referred to as “cookies”), that may collect or store Personal Data. Cookies are text files stored and used to record Non-Personal and Personal Data concerning Your browsing and use of the Site. Cookies can be either persistent (i.e., remain after You logoff from the Site in order to be used on Your subsequent visits to the Site) or transient (i.e., removed when You close the web browser). AWL may use cookies in order to: – improve Your user experience through, for example: enabling a service to recognize Your device so You don’t have to give the same information several times during one task; recognizing that You may already have given a username and password so You don’t need to do so for every web page requested; – analyze traffic and data on the Site to: measure how many people are using the Site, so the Site can be made easier to use and navigate and to make sure there is enough capacity to ensure the Site have adequate response times; help AWL understand how users interact with the Site so AWL can improve their functionality and performance. AWL may also use third-party services to perform services on its behalf, in particular to: – analyze Your browsing habits and measure the Site audience, – analyze Your interests and offer You targeted marketing or advertising, – allow You to share content from the services with other people on social networks or to let these other people know what You are looking at or what You think (e.g., the “Like” button on Facebook) In such a case, cookies provided by such third-party vendors may be used and stored. By transmitting the information generated by these cookies, the cookies’ settings ensure that an IP address is anonymized before geo-localization and before storage. Our providers will use this information for the evaluation of Your use of the Site, compiling reports on the Site activity for AWL, to propose better services to You that are suited to Your needs, and display advertisements You that are suited to Your needs. Cookies will not associate Your IP address with any other data they hold. When You browse the Site, cookies are enabled by default and data may be read from or stored locally on Your device if Your browser settings allow. You will be notified of the use of cookies the first time You access the Site with a different device; AWL will not install any cookies before obtaining Your explicit consent. You may decide to accept or refuse some or all cookies. You can configure Your browser software to refuse all cookies (including cookies used for web analytics services); if You do so, however, some areas and features of the Site may not function properly and/or You may not be able to access some parts or services of the Site.

10. LINKS TO WEBSITES NOT CONTROLLED BY AWL OR ITS SUBSIDIARIES

The Site might offer links to third-party websites that may be of interest to You. AWL does not exercise any control over the content of third-party websites or the practices of these third-parties in connection with the protection of Personal Data that they might collect and are thus not in the control of AWL. Consequently, AWL shall have no liability for the content of third-party websites or the practices of these third-parties concerning the protection of Personal Data. It is therefore Your responsibility to inform yourself of the privacy policies of these third-party websites.

11. DISPUTE RESOLUTION

Although AWL has put in place reasonable safeguards to protect Personal Data, AWL recognizes that there is no method of transmitting or storing Personal Data that is completely secure. However, AWL is committed to ensure the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact info@awlonline.org AWL will investigate and attempt to resolve complaints regarding use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy. Unauthorized access to Personal Data or the improper use of Personal Data may constitute offenses under local law.

12. CONTACT

For any additional question concerning this Privacy Policy, to opt out of receiving information from AWL or any request regarding Your rights in Your Personal Data You may send an email to: info@awlonline.org

13. DATE OF ENTRY INTO FORCE OF THE PRIVACY POLICY AND CHANGES TO IT

This Privacy Policy may be updated according to AWL’ requirements and circumstances, or where required by applicable laws and regulations so please check back periodically for updates. If major changes occur to this Privacy Policy, AWL may inform You via email or via posting a notice on the Site.

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