BEST Website Privacy Policy

Effective Date: May 31, 2016

Businesses Ending Slavery and Trafficking (“BEST,” “we,” “us,” or “our”) is committed to protecting your privacy.  This Privacy Policy (“Policy”) describes how we collect, use, store, process, and share your information in relation to the BEST website (http://www.bestalliance.org/) and/or Training Center website (http://www.bestalliance.staging.wpengine.com/) (referred to herein, individually or collectively, as the “Site”).  Please review this Policy carefully, as well as our Terms of Use (“Terms”) governing your use of the Site, which can be viewed at: http://bestalliance.wpengine.com/terms-conditions/.  This Policy is part of and incorporated into the Terms.  Capitalized terms used but not defined herein have the definitions set forth in the Terms.  By accessing, browsing, or using the Site, you expressly consent to the collection, use, storage, processing, and disclosure of your information, including personally identifiable information, as described in this Policy.  If you do not agree with this policy or our Terms, you should not access or use the site or purchase products through the Site.

If you have any questions about this Policy, please contact us at: info@bestalliance.org.

  1. Changes to this Policy

We reserve the right to revise this Policy from time to time by updating it and posting it at http://bestalliance.wpengine.com/privacy-policy, with the new terms taking effect on the date of posting.  You should periodically review this Policy to ensure you are familiar with the most current version.  Your use of the Site after the Effective Date posted above constitutes your acceptance of the updated Policy.

  1. Information Collection

A. General. When you visit the Site, you can browse without submitting any personal information about yourself.  We will, however, receive and store some non-personally identifiable information about you, as described below.  In order to participate in certain functionalities, including registering, using, or accessing your Account, you may be asked to provide personally identifiable information.  “Personally identifiable information” is information that can identify you, including, for example, your name or email address.  It will always be your choice, or the choice of anyone acting for you, to provide personally identifiable information.

B. Orders and Payment Processing. If you purchase Products from or make donations to us, we request certain personally identifiable information from you on our payment forms.  This includes, but is not limited to, name, email address, and billing address, and, where applicable, financial information, which includes, but is not limited to, credit card number, expiration date, and validation number.  We use this information for billing purposes and to fulfill your orders.  If we have trouble processing an order, we, or our third party payment processor, may use this information to contact you.

We use a third party payment processor (currently Stripe) to assist in securely processing your personally identifiable payment information.  The credit card information that you provide is encrypted and transmitted directly to Stripe.  We do not store your credit card information and do not control and are not responsible for Stripe or its collection or use of your information.  You may find out more about how Stripe stores and uses your credit card information by accessing the Stripe Privacy Policy.

C. Account and Login Information. We will collect personally identifiable information from you when you create an Account.  If you create an Account, you will be asked to provide information about yourself, including, but not limited to, name, email address, billing address, and password selected by you.

D. User Comments. You may be permitted to post user comments in response to certain Content, such as articles.  You may only post user comments by logging in through Facebook.  We may save user comments, materials, or other content you post indefinitely.

 E. Email Address Collection; BEST Newsletter. In order to receive certain communications from us, including, but not limited to, our BEST Newsletter, you may be required to submit your name and email address to us.  Any email communication you receive from us will include our contact information and an unsubscribe link that will allow you to opt-out of receiving future emails.

F. Requests or Communications Submitted by You. The Site provides users the option to submit questions, feedback, or comments by filling out a form available under the “Contact BEST” link at the bottom of the homepage.  This form asks for your name and email address and we will use this information to respond to your inquiries.  Any communications and contact information that you voluntarily submit to us may be saved indefinitely and in a profile specific to you.

G. Employers Alliance Self-Assessment. Participants in the Employers Alliance may be asked to complete a Self-Assessment.  We will collect non-personally and personally identifiable information through this Self-Assessment that you choose to give us.  Use of such information will be in accordance with this Policy and any terms included with the Self-Assessment.

H. Training Surveys. We may provide you the opportunity to participate in surveys on the Site.  We will request certain personally identifiable information through those surveys.  Use of such information will be in accordance with this Policy and any terms included with the survey.

I. Automatically Collected Information. Similar to other websites, we may collect some information automatically and store it in log files, regardless of whether you create an Account.  This information does not identify you.  This collection may include, but is not limited to: your domain name and host for Internet access, the Internet address of the site from which you came, the date and time of your access, your computer’s IP address and information about its operating system, browser, and host, the date and time you access the Site, and the pages you visit.  We collect this non-personally identifying information in order to help diagnose problems with our server and to administer the Site.

Cookies.  We may automatically collect information using cookies.  A cookie is a small text file that is stored on a computer for record-keeping purposes.  We use cookies for analyzing trends, site administration, tracking user movement, and to gather demographic information from our base as a whole.  Some cookies remain on your computer until you delete them.  Others, like session ID cookies, expire when you close your browser.  You may set your browser setting to attempt to reject cookies and you may still use the Site, however, certain features of the Site may not be available if your browser does not accept cookies.  See “Do-Not Track Settings” below for more information on how use of the Site may or may not be affected by your browser settings.  We do not control the use of cookies by third parties.  Also see “Third Party Analytics Providers” below.

J. Third Party Analytics Providers. We use third parties to help us operate and improve the Site.  In doing so, we may share with these third parties non-personally identifiable information about users’ use of the Site.  These third party providers also use cookies.  We use third party analytics providers, such as Google Analytics, to provide us with general demographic and interest-level information about our users and to help create a better user experience.  We do not control information collected by third parties and are not responsible for their use of that information.  For more information regarding Google’s use of cookies and collection and use of information see the Google Privacy Policy.  To opt out of Google Analytics, please visit the Google Analytics Opt-Out Page to learn about opting out and installing the appropriate browser add-on.

K. “Do Not Track” Settings. Because we track website usage information as described above, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of certain information. The only way to completely “opt out” of the collection of information through cookies or other tracking technologies is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website may not be able to control other websites.

  1. Information Use

A. Use of Personally Identifiable Information. We may use your personally identifiable information that you provide us, such as your email address, to send you occasional updates and our BEST Newsletter.  You may also receive emails or other communications from us in response to inquiries that you submit to contact us or request more information regarding our Site, Content, and training opportunities.  When you receive a promotional or informational email communication from us, the email will contain our contact information and an unsubscribe link that will allow you to opt-out of future emails from us.  If you opt-out, you will still continue to receive email responses to your inquiries or other service-related emails related to your use of the Site.  We may also use personally identifiable information to resolve disputes; to detect and protect against errors, fraud, and criminal activity; to assist law enforcement; to enforce this Policy and the Terms; or for any other purpose described in this Policy or that we describe to you at the time of collection.

B. Use of Non-Personally Identifiable Information. We may use non-personally identifiable information for any lawful purpose, including, but not limited to analyzing trends, administering the Site, tracking users’ movements on the Site, and for management and improvement of the Site.  We may also use this information to store information about your device so that you will not have to re-enter it the next time you visit the Site; to monitor aggregate metrics such as total number of visitors or pages viewed; or to track submissions in any interactive portion of the Site.  We may also combine non-personally identifiable information with non-personally identifiable information collected from other sources.

C. Information Retention. We will retain your information indefinitely, or as long as legally required or allowed. We may dispose of any information in our discretion without notice, subject to applicable law.  We do not undertake any retention obligations through this statement.

  1. Information Disclosure

A. Affiliated Entities or Service Providers. We will not sell or rent any of your personal information to third parties for marketing p  We may use third parties to help us operate the Site.  For instance, we use Stripe, a credit card processing company, to process payments, and we may use third party service providers to provide advertising and analytics information for our Site.  See “Orders and Payment Processing” and “Third Party Analytics Providers” above for more information.

B. User Comments. If you submit user comments to any portion of the Site, your comments will be made publicly available to anyone who visits that area of the Site.  Other users or the general public may access, re-post, or use user comments that you make publicly available through the Site.  Even if you remove or delete your comments, copies may remain in cached or archived areas of the Site.  If you share content with Linked Sites, such as Facebook, the content you share will be subject to that site’s privacy policy.

C. Business Transition. In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, we may transfer your personally identifiable information in connection with the business transition.

D. Legal Requirements. In some cases, we may disclose your information (a) as required by any applicable law or legal regulation; (b) if we believe disclosure is needed to protect our rights, property, or safety; (c) to government regulators or law enforcement authorities in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Site; and (d) to respond to a physical threat to you or another person.

E. Disclaimer. Due to the complexity and open nature of the Internet, no transmission of data over the Internet can be 100% secure.  There is always a risk that information collected by and/or displayed on the Site may be compromised or accessed notwithstanding the steps we take to secure your information.  For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the Site may abuse or misuse your personal information.

  1. Information Security Measures

Keeping your information secure is of great concern to us. We exercise care in facilitating the transmission of information between your device or computer and our servers (or the third party servers that operate and store information for the Site).  Personally identifiable information collected by the Site is stored in operating environments that are not available to the public.  While we have mechanisms in place to safeguard your personal information after we receive it, no transmission of data over the internet can be 100% secure.

  1. Children’s Privacy

A. This Site is Not for or Directed Towards Children. Our primary audience is adults.  We do not intend to and will not knowingly collect any personal information from children under the age of 13, and children under the age of 13 are prohibited from using the Site without parent/guardian supervision.  If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers (subject to applicable law and this Policy).  If you believe content from a child under the age of 13 has been posted to the Site, please notify us by going to the “Contact BEST” link at the bottom of the home page.

B. California Minors. If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: info@bestalliance.org.  When requesting removal, please be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it.  We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you do not follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information.  REMOVAL OF YOUR CONTENT OR INFORMATION FROM THE SITE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS.  We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

  1. California Shine the Light Law

California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them.  If you are a California resident and you wish to make such a request, you may do so by contacting us as specified in Section 10 below.

  1. Linked Sites

The Site contains links to other websites (“Linked Sites”).  We have no control over, and are not liable or responsible for the privacy practices, terms of use, or content of Linked Sites.  The Linked Sites may collect personally identifiable information from you that is not subject to our control.  The data collection practices of Linked Sites will be governed by that site’s privacy policy.  Please review the privacy policies of any Linked Sites you may access.

  1. Accessing, Updating, or Deleting your Personal Information

If personal information that you have submitted to us changes or if you would like to remove your personal information, please contact us as specified in Section 10 below. We will make good faith efforts to resolve requests to remove information or correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.

  1. Contact Information and Privacy Questions

If you have questions about this Policy or other matters that relate to it, you may contact us by going to the “Contact BEST” link at the bottom of our home page and using the form located there, or by contacting us at: info@bestalliance.org.