[DRAFT] Last updated on September 18, 2020
Who We Are
Policy Futures Network is a Limited Liability Company founded in 2019 by Harry Conaway (Executive Director) and licensed in Washington DC. See the About PFN for more information. The current PFN website is at https://policyfutures.net.
Users provide information to PFN when they create an account or profile, fill out a form, submit or post content through any PFN Service, sign up for a membership, communicate with PFN via third-party platforms, online form, email, customer support, or otherwise communicate with PFN or its officers, directors, employees, or contractors. The types of User information may include a User’s name, display name, username, bio, email address, business information, and content, including avatar image, photos, posts, comments, and any other information the User chooses to provide.
In some cases, PFN may also collect information Users may provide about others, such as when a User provides a PFN membership for another person or a User suggests or contributes content to any PFN Service. PFN will use this information to fulfill the User’s request and will not send communications to the User’s contacts unrelated to the User’s request, unless the contacts separately consent to receive communications from or otherwise engage with PFN.
In some instances, PFN automatically collects certain information, including:
- Activity Information: PFN collects information about Users’ activities on PFN Services, such as reading histories, shared links, followed users, highlighted posts, and provided comments.
- Transactional Information: When Users sign up or register for memberships, PFN collects information about the transactions, such as information about the Users, subscription details, purchase prices, and the dates of the transactions.
- Device and Usage Information: PFN collects information about how Users access PFN Services, including data about the Users’ devices and networks, such as hardware models, operating system versions, mobile networks, IP addresses, unique device identifiers, browser types, and app versions. PFN also collects information about Users’ activities on PFN Services, such as access times, pages viewed, links clicked, and the pages that Users visited before navigating to or within PFN Services.
PFN obtains some information from third-party sources. For example, PFN may collect information about Users from social networks, accounting services providers, and data analytics providers. Additionally, if a User creates or logs into PFN through a third-party platform (such as Apple, Facebook, Google, or Twitter), PFN may have access to certain information from that platform, such as name, friends or followers, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.
Use of Information
PFN uses information it collects or receives to provide, maintain, and improve PFN Services, which includes publishing and distributing User-generated content, personalizing the posts and content Users may access, and operating PFN memberships. PFN also uses the information to:
- Create and maintain Users’ memberships, newsletter subscriptions, access rights, and profiles;
- Process transactions and send related information, such as confirmations, receipts, and user experience surveys;
- Send technical notices, security alerts, and support and administrative messages;
- Respond to comments and questions and provide customer service;
- Communicate about new content, products, services, and features offered by PFN and provide other news and information;
- Monitor and analyze trends, usage, and activities in connection with PFN Services;
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of PFN and others;
- Debug to identify and repair errors in PFN Services;
- Comply with legal and financial obligations applicable to PFN; and
- Carry out any other purpose described when the information was collected.
PFN shares information in the following circumstances or as otherwise described in this policy:
- PFN shares information with other Users of PFN Services. For example, if a User uses a PFN Service to publish content, post comments or send private notes, certain information about the User will be visible to others, such as name, photo, bio, other profile information, and information about the User’s activities on PFN Services (e.g., followers, recent posts, claps, highlights, and responses).
- PFN shares information with vendors, service providers, contractors, and consultants who need access to information in order to perform services for PFN, such as companies (and their employees, contractors, and consultants) that assist with web hosting, storage, and other infrastructure; analytics; payment processing; fraud prevention and security; customer service; communications; and marketing.
- PFN may disclose information if PFN believes that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If PFN is going to disclose information in response to alegal process, PFN will notify the User so the User has the opportunity to challenge it (e.g., by seeking court intervention), unless PFN is prohibited by law or believes doing so may endanger others or cause illegal conduct. PFN will object to legal requests for information about Users of PFN Services that PFN believes are improper.
- PFN may share information if PFN believes that a User’s actions are inconsistent with PFN agreements or policies, if PFN believes that a User may have violated the law, or if PFN believes it is necessary to protect the rights, property, and safety of PFN, our Users, the public, or others.
- PFN may share information with PFN lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage PFN’s business interests.
- PFN may share information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is shared between and among PFN and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- PFN may share information with the User’s consent or at the User’s direction.
- PFN may share aggregated or de-identified information that cannot reasonably be used to identify any particular User.
PFN does not sell any User’s personal information.
Additional Discussion about Information Associated with Accounts, Profiles, Comments, and Content
When a User creates an account or profile or leaves comments on a PFN Service, PFN collects the data shown in the account, profile, or comments form, as well as the User’s IP address and browser user agent string to help spam detection.
If a User leaves a comment on a PFN Service, the User may opt in to saving the User’s name, email address, and website in cookies. These are for the User’s convenience so that the User does not have to fill in his or her details again when the User leaves another comment. These cookies will last for one year.
Also, if a User leaves a comment on a PFN Service, the comment and its metadata are retained indefinitely. This is so PFN can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
If a User has an account, profile, or membership and logs in to a PFN Service, PFN will set a temporary cookie to determine whether the User’s browser accepts cookies. This cookie contains no personal data and is discarded when the User closes his or her browser.
Also, when a User logs into a PFN Service, PFN will set up several cookies to save the User’s login information and screen display choices. Login cookies last for two days, and screen options cookies last for a year. If a User selects “Remember Me,” the User’s login will persist for two weeks. If the User logs out of the PFN Service, the login cookies will be removed.
For Users who register or create an account or profile on a PFN Service, PFN also stores the personal information the User provides in his/her profile. All Users can see, edit, or delete their information at any time (except Users cannot change their usernames). Website administrators can also see and edit that information.
If a User edits or publishes content on a PFN Service, an additional cookie will be saved in the User’s browser. This cookie includes no personal data and simply indicates the post ID of the content the User edited or published. It expires after one day.
Users should avoid uploading images with embedded location data (EXIF GPS) included. Users of a PFN Service can download and extract any location data from images.
If a User has an account on a PFN Service or has left comments, the User can request to receive an exported file of the personal data PFN holds about the user, including any data the User has provided. The User can also request that PFN erase any personal data PFN holds about the User. This does not include any data PFN is obliged to keep for administrative, legal, or security purposes.
Account information. A User may access, correct, delete and export his or her account and profile information at any time by logging into the PFN Service. Please note that if a User chooses to delete his or her account or profile, PFN may retain certain information about the User as required by law or for legitimate PFN business purposes.
Cookies. Most web browsers are set to accept cookies by default. If a User prefers, the User can usually adjust browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of PFN Services.
Communication preferences. A User may opt out of receiving certain communications from PFN, such as newsletters, emails, activity notifications, and marketing or promotional communications, by following the instructions in those communications. If a User opts out, PFN may still send administrative emails, such as those about the User’s account or ongoing business relations.
Mobile push notifications. With a User’s consent, PFN may send push notifications to a User’s mobile device. A User can deactivate these messages at any time by changing the notification settings on his or her mobile device.
California Privacy Rights
The California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.) or “CCPA” affords consumers residing in California certain rights with respect to their personal information. This section applies to users who are California residents.
During the preceding 12 months, PFN has collected the following categories of personal information: identifiers, commercial information, internet or other electronic network activity information, and inferences. For details about the precise data points PFN collects and the categories of sources of such collection, please see above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Subject to certain limitations, California Users have the right to (1) request to know more about the categories and specific pieces of personal information PFN collects, uses, and discloses about the User, (2) request deletion of the User’s personal information, (3) opt out of any sales of the User’s personal information, if PFN engages in that activity in the future, and (4) not be discriminated against for exercising these rights. A User may make these requests by emailing PFN at firstname.lastname@example.org. PFN will not discriminate against a User if the User exercises his or her rights under the CCPA.
If PFN receives a request from an authorized agent, PFN may ask for evidence that the User has provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on the User’s behalf. This may include requiring the User to verify his or her identity. For more information, please email PFN at email@example.com.
Users in Europe
If a User is located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the User has certain rights and protections under applicable law regarding the processing of personal data.
When PFN processes personal data, PFN will do so in reliance on the following lawful bases:
- To perform PFN responsibilities under the PFN’s contract with the User (e.g., providing the products and services the User requested).
- When PFN has a legitimate interest in processing the User’s personal data to operate PFN business or protect PFN interests (e.g., to provide, maintain, and improve products and services, conduct data analytics, and communicate).
- To comply with PFN’s legal obligations (e.g., to maintain a record of a User’s consents and track those who have opted out of non-administrative communications).
- When PFN has a User’s consent to do so (e.g., when a User opts in to receive non-administrative communications from PFN). When consent is the legal basis for processing a User’s personal data, the User may withdraw such consent at any time.
PFN stores personal data associated with a User’s account or membership for as long as the account or membership remains active. If a User closes his or her account or stops his or her membership, PFN will delete the User’s account and profile data within 14 days. PFN stores other personal data for as long as necessary to carry out the purposes for which PFN originally collected it and for other legitimate business purposes, including to meet legal, regulatory, or other compliance obligations.
Subject to certain limitations, a User has the right to request access to the personal data PFN holds about the User and to receive the User’s data in a portable format, the right to ask that the User’s personal data be corrected or erased, and the right to object to, or request that PFN restrict, certain processing. To exercise a User’s rights:
- If a User signs up for a PFN account or membership, the User may at any time request an export of his or her personal information.
- A User may correct information associated with the User’s account.
- A User may withdraw consent by deleting or stopping the User’s account or membership at any time (except to the extent PFN is prevented by law from deleting the User’s information).
- A User may object at any time to the use of the User’s personal data by contacting PFN at firstname.lastname@example.org.
If a User has a concern about the processing of personal data that PFN is not able to resolve, the User has the right to lodge a complaint with the Data Protection Authority where the User resides. Contact details for the User’s Data Protection Authority can be found using the links below:
- For individuals in the EEA:
- For individuals in the UK:
- For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
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