This policy explains how we (Global Citizen Forum) use any personal information we collect about you when you register to receive E-mail and Whatsapp newsletters from us. By registering for this service, you consent to the collection, retention and use of your personal information in accordance with the terms of this policy.
We collect information about you when you register for this service by opting in when you sign on.
The information you provide will be used to send you newsletters,
via e-mail using MailChimp and Whatsapp.
You have the right to request a copy of the information that we hold about you. If you would like a copy of this information, please contact us. We want to make sure that your information is accurate and up to date. You may also ask us to correct or remove any inaccurate information.
You can opt out from further communications at any point by selecting the unsubscribe link at the bottom of the newsletter. You can also contact us directly to request that you are removed from our mailing list.
6.1 MailChimp (“MailChimp,” “we,” or “us”) is an online marketing
platform (the “Service”) offered through the URL www.mailchimp.com
(we’ll refer to it as the “Website”) that allows you to, among other
things, create, send, and manage certain marketing campaigns,
including, without limitation, emails, advertisements, and mailings
(each a “Campaign,” and collectively, “Campaigns”). MailChimp is a
Georgia limited liability company whose legal name is The Rocket
Science Group LLC d/b/a MailChimp. MailChimp has employees,
independent contractors, and representatives (“our Team”). As a
customer of the Service or a representative of an entity that’s a
customer of the Service, you’re a “Member” according to this
Agreement (or “you”).
Effective July 23, 2018
7.1 MailChimp is an online marketing platform (the "Services") operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States ("we," "us," "our," and "MailChimp"). The Services enable our Members to, among other things, send and manage email campaigns and serve advertisements. We also provide other related services, such as real-time data analytics.
7.3 "Member" means any person or entity that is registered with us to use the Services.
We may share and disclose your Personal Information to the following
types of third parties for the purposes described in this privacy
policy (for purposes of this section, "you" and "your" refer to
Members, Contacts, and Visitors unless otherwise indicated):
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information of Members and Visitors with them for this purpose. We do not sell or market to any of our Members’ Contacts.
iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.
(v) Any other person with your consent.
If you are from the European Economic Area, our legal basis for
collecting and using the Personal Information described above will
depend on the Personal Information concerned and the specific
context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
Members and Visitors who have opted in to our marketing emails can
opt out of receiving marketing emails from us at any time by
clicking the "unsubscribe" link at the bottom of our marketing
Also, all opt-out requests can be made by emailing us using the contact details. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Members cannot opt out of these messages unless you cancel your MailChimp account.
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. MailChimp accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s MailChimp account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.
(1) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Members a Data Processing Agreement.
(2) Data transfers from Switzerland or the EU to the United States
MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all Personal Information received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to each Framework’s applicable Principles.
MailChimp is responsible for the processing of Personal Information we receive under each Privacy Shield Framework and subsequently transfer to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
Members located in Switzerland and the EU should also request our data processing agreement, where you will be directed to log in to your account to sign the agreement online, in addition to relying on MailChimp’s Privacy Shield certification.
(3) Members located in Australia:
If you are a Member who lives in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 ("Australian Privacy Act"). Here are the specific points you should be aware of:
requiring our subcontractors to undertake a similar obligation, where relevant. We will not use or disclose Personal Information for the purpose of our direct marketing to you unless you have consented to receive direct marketing; you would reasonably expect us to use your personal details for the marketing; or we believe you may be interested in the material but it is impractical for us to obtain your consent. You may opt out of any marketing materials we send to you through an unsubscribe mechanism or by contacting us directly. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as "direct marketing" under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account.
Our servers are located in the United States. In addition, we or our subcontractors may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas. If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request.
If you are unsatisfied with our response to a privacy matter then you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.
We retain Personal Information where we have an ongoing legitimate
business or legal need to do so. Our retention periods will vary
depending on the type of data involved, but, generally, we'll refer
to these criteria in order to determine retention period:
Whether we have a legal or contractual need to retain the data.
Whether the data is necessary to provide our Services.
Whether our Members have the ability to access and delete the data within their MailChimp accounts.
Whether our Members would reasonably expect that we would retain the data until they remove it or until their MailChimp accounts are closed or terminated. 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.
WhatsApp Inc. (“WhatsApp,” “our,” “we,” or “us”) provides messaging,
Internet calling, and other services to users around the world.
Please read our Terms of Service so you understand what’s up with
your use of WhatsApp. You agree to our Terms of Service (“Terms”) by
installing, accessing, or using our apps, services, features,
software, or website (together, “Services”).
If you are a whatsapp user located in the United States or Canada, our terms contain a binding arbitration provision, which states that, except if you opt out and except for certain types of disputes, whatsapp and you agree to resolve all disputes through binding individual arbitration, which means that you waive any right to have those disputes decided by a judge or jury, and that you waive your right to participate in class actions, class arbitrations, or representative actions. Please read the “special arbitration provision for United States or Canada users” section below to learn more.
You must use our Services according to our Terms and posted policies. If we disable your account for a violation of our Terms, you will not create another account without our permission.
You must access and use our Services only for legal, authorized, and
acceptable purposes. You will not use (or assist others in using)
our Services in ways that: (a) violate, misappropriate, or infringe
the rights of WhatsApp, our users, or others, including privacy,
publicity, intellectual property, or other proprietary rights; (b)
are illegal, obscene, defamatory, threatening, intimidating,
harassing, hateful, racially, or ethnically offensive, or instigate
or encourage conduct that would be illegal, or otherwise
inappropriate, including promoting violent crimes; (c) involve
publishing falsehoods, misrepresentations, or misleading statements;
(d) impersonate someone; (e) involve sending illegal or
impermissible communications such as bulk messaging, auto-messaging,
auto-dialing, and the like; or (f) involve any non-personal use of
our Services unless otherwise authorized by us.
Harm to WhatsApp or Our Users. You must not (or assist others to) access, use, copy, adapt, modify, prepare derivative works based upon, distribute, license, sublicense, transfer, display, perform, or otherwise exploit our Services in impermissible or unauthorized manners, or in ways that burden, impair, or harm us, our Services, systems, our users, or others, including that you must not directly or through automated means: (a) reverse engineer, alter, modify, create derivative works from, decompile, or extract code from our Services; (b) send, store, or transmit viruses or other harmful computer code through or onto our Services; (c) gain or attempt to gain unauthorized access to our Services or systems; (d) interfere with or disrupt the integrity or performance of our Services; (e) create accounts for our Services through unauthorized or automated means; (f) collect the information of or about our users in any impermissible or unauthorized manner; (g) sell, resell, rent, or charge for our Services; or (h) distribute or make our Services available over a network where they could be used by multiple devices at the same time.
Our Services may allow you to access, use, or interact with third-party websites, apps, content, and other products and services. For example, you may choose to use third-party data backup services (such as iCloud or Google Drive) that are integrated with our Services or interact with a share button on a third party’s website that enables you to send information to your WhatsApp contacts. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
WhatsApp does not claim ownership of the information that you submit for your WhatsApp account or through our Services. You must have the necessary rights to such information that you submit for your WhatsApp account or through our Services and the right to grant the rights and licenses in our Terms.
We own all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with our Services. You may not use our copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights unless you have our express permission and except in accordance with our Brand Guidelines. You may use the trademarks www.facebookbrand.com/trademarks of our affiliated companies only with their permission, including as authorized in any published brand guidelines.
We grant you a limited, revocable, non-exclusive, non-sublicensable, and non-transferable license to use our Services, subject to and in accordance with our Terms. This license is for the sole purpose of enabling you to use our Services, in the manner permitted by our Terms. No licenses or rights are granted to you by implication or otherwise, except for the licenses and rights expressly granted to you.
You use our services at your own risk and subject to the following disclaimers. we are providing our services on an “as is” basis without any express or implied warranties, including, but not limited to, warranties of merchantability, fitness for a particular purpose, title, non-infringement, and freedom from computer virus or other harmful code. we do not warrant that any information provided by us is accurate, complete, or useful, that our services will be operational, error free, secure, or safe, or that our services will function without disruptions, delays, or imperfections. we do not control, and are not responsible for, controlling how or when our users use our services or the features, services, and interfaces our services provide. we are not responsible for and are not obligated to control the actions or information (including content) of our users or other third parties. you release us, our subsidiaries, affiliates, and our and their directors, officers, employees, partners, and agents (together, the “whatsapp parties”) from any claim, complaint, cause of action, controversy, or dispute (together, “claim”) and damages, known and unknown, relating to, arising out of, or in any way connected with any such claim you have against any third parties. you waive any rights you may have under California civil code §1542, or any other similar applicable statute or law of any other jurisdiction, which says that: a general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor.
You agree to defend, indemnify, and hold harmless the WhatsApp Parties from and against all liabilities, damages, losses, and expenses of any kind (including reasonable legal fees and costs) relating to, arising out of, or in any way in connection with any of the following: (a) your access to or use of our Services, including information provided in connection therewith; (b) your breach or alleged breach of our Terms; or (c) any misrepresentation made by you. You will cooperate as fully as required by us in the defense or settlement of any Claim.
If you are a WhatsApp user located in the United States or Canada, the “Special Arbitration Provision for United States or Canada Users” section below applies to you. Please also read that section carefully and completely. If you are not subject to the “Special Arbitration Provision for United States or Canada Users” section below, you agree that you will resolve any Claim you have with us relating to, arising out of, or in any way in connection with our Terms, us, or our Services (each, a “Dispute,” and together, “Disputes”) exclusively in the United States District Court for the Northern District of California or a state court located in San Mateo County in California, and you agree to submit to the personal jurisdiction of such courts for the purpose of litigating all such Disputes.
The laws of the State of California govern our Terms, as well as any Disputes, whether in court or arbitration, which might arise between WhatsApp and you, without regard to conflict of law provisions.
We may modify, suspend, or terminate your access to or use of our Services anytime for any reason, such as if you violate the letter or spirit of our Terms or create harm, risk, or possible legal exposure for us, our users, or others. The following provisions will survive any termination of your relationship with WhatsApp: “Licenses,” “Disclaimers,” “Limitation of Liability,” “Indemnification,” “Dispute Resolution,” “Availability and Termination of our Services,” “Other,” and “Special Arbitration Provision for United States or Canada Users.”
Last modified: August 25, 2016 (archived versions)
WhatsApp receives or collects information when we operate and provide our Services, including when you install, access, or use our Services.
You provide your mobile phone number to create a WhatsApp account. You provide us the phone numbers in your mobile address book on a regular basis, including those of both the users of our Services and your other contacts. You confirm you are authorized to provide us such numbers. You may also add other information to your account, such as a profile name, profile picture, and status message.
We do not retain your messages in the ordinary course of providing our Services to you. Once your messages (including your chats, photos, videos, voice messages, files, and share location information) are delivered, they are deleted from our servers. Your messages are stored on your own device. If a message cannot be delivered immediately (for example, if you are offline), we may keep it on our servers for up to 30 days as we try to deliver it. If a message is still undelivered after 30 days, we delete it. To improve performance and deliver media messages more efficiently, such as when many people are sharing a popular photo or video, we may retain that content on our servers for a longer period of time. We also offer end-to-end encryption for our Services, which is on by default, when you and the people with whom you message use a version of our app released after April 2, 2016. End-to-end encryption means that your messages are encrypted to protect against us and third parties from reading them.
You may provide us with information related to your use of our
Services, including copies of your messages, and how to contact you
so we can provide you customer support. For example, you may send us
an email with information relating to our app performance or other
Automatically Collected Information
We collect service-related, diagnostic, and performance information. This includes information about your activity (such as how you use our Services, how you interact with others using our Services, and the like), log files, and diagnostic, crash, website, and performance logs and reports.
If you pay for our Services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment.
We collect device-specific information when you install, access, or use our Services. This includes information such as hardware model, operating system information, browser information, IP address, mobile network information including phone number, and device identifiers. We collect device location information if you use our location features, such as when you choose to share your location with your contacts, view locations nearby or those others have shared with you, and the like, and for diagnostics and troubleshooting purposes such as if you are having trouble with our app’s location features.
We receive information other people provide us, which may include information about you. For example, when other users you know use our Services, they may provide your phone number from their mobile address book (just as you may provide theirs), or they may send you a message, send messages to groups to which you belong, or call you.
We work with third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems, supply map and places information, process payments, help us understand how people use our Services, and market our Services. These providers may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues.
We allow you to use our Services in connection with third-party
services. If you use our Services with such third-party services, we
may receive information about you from them; for example, if you use
the WhatsApp share button on a news service to share a news article
with your WhatsApp contacts, groups, or broadcast lists on our
Services, or if you choose to access our Services through a mobile
carrier’s or device provider’s promotion of our Services. Please
note that when you use third-party services, their own terms and
privacy policies will govern your use of those services.
How We Use Information
We use all the information we have to help us operate, provide, improve, understand, customize, support, and market our Services.
We operate and provide our Services, including providing customer
support, and improving, fixing, and customizing our Services.
We verify accounts and activity, and promote safety and security on
and off our Services, such as by investigating suspicious activity
or violations of our Terms, and to ensure our Services are being
Communications about Our Services and the Facebook Family of Companies. We communicate with you about our Services and features and let you know about our terms and policies and other important updates. We may provide you marketing for our Services and those of the Facebook family of companies, of which we are now a part.
No Third-Party Banner Ads. We do not allow third-party banner ads on WhatsApp. We have no intention to introduce them, but if we ever do, we will update this policy.
We will allow you and third parties, like businesses, to communicate
with each other using WhatsApp, such as through order, transaction,
and appointment information, delivery and shipping notifications,
product and service updates, and marketing. For example, you may
receive flight status information for upcoming travel, a receipt for
something you purchased, or a notification when a delivery will be
made. Messages you may receive containing marketing could include an
offer for something that might interest you. We do not want you to
have a spammy experience; as with all of your messages, you can
manage these communications, and we will honor the choices you
Information You And We Share
You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services.
We work with third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services. When we share information with third-party providers, we require them to use your information in accordance with our instructions and terms or with express permission from you.
When you use third-party services that are integrated with our Services, they may receive information about what you share with them. For example, if you use a data backup service integrated with our Services (such as iCloud or Google Drive), they will receive information about what you share with them. If you interact with a third-party service linked through our Services, you may be providing information directly to such third party. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
If you would like to manage, change, limit, or delete your information, we allow you to do that through the following tools:
You can change your Services settings to manage certain information available to other users. You can manage your contacts, groups, and broadcast lists, or use our block feature to manage the users with whom you communicate.
You may delete your WhatsApp account at any time (including if you want to revoke your consent to our use of your information) using our in-app delete my account feature. When you delete your WhatsApp account, your undelivered messages are deleted from our servers as well as any of your other information we no longer need to operate and provide our Services. Be mindful that if you only delete our Services from your device without using our in-app delete my account feature, your information may be stored with us for a longer period. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of the messages you sent them.
We may collect, use, preserve, and share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond pursuant to applicable law or regulations, to legal process, or to government requests; (b) enforce our Terms and any other applicable terms and policies, including for investigations of potential violations; (c) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our users, WhatsApp, the Facebook family of companies, or others.