Worker Connect Dashboard PRIVACY POLICY

 

Last modified: July 2018

 

This privacy policy (the "Privacy Policy") is intended to inform you of the policies and procedures of Caravan Studios, a division of TechSoup Global (“Caravan Studios,” "we," or "us"). We take the privacy and protection of your Personal Information (as defined below) very seriously. We may collect Personal Information from you in accordance with the terms of this Privacy Policy when you use the Worker Connect online dashboard or visit websites operated by us (all or any part of which we refer to herein as "Worker Connect").

 

This Privacy Policy is intended to inform the general public about the types of data we collect and how we collect it, as well as how we use, process, and disclose your information, including Personal Information, in conjunction with your access to and use of Worker Connect. Generally, if we process data, we will ensure that there is a statutory basis for such processing (defined below), or we will obtain consent.  Processing of Personal Information, such as names, address, e-mail address, or telephone number shall always be in line with the General Data Protection Regulation (“GDPR”), and in accordance with any applicable country-specific data protection regulations.

 

If you see an undefined term in this Privacy Policy, it has the same definition as in our Terms of Use, or the terms used by the European legislature for the adoption of the GDPR.

 

For purposes of GDPR, TechSoup Global (including Caravan) is a Controller (defined below). As discussed herein, you can contact us at any time to: request access to information that we have about you; correct any information we have about you; and/or delete information that we have about you.  If you have additional questions about our data collection or storage, please contact us at privacy@techsoup.org.

​

Definitions

 

“Anonymous Information” means information not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individuals.

 

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law

 

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

“Process” or “Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

General Security

 

We take commercially reasonable physical, electronic, and managerial precautions to prevent the loss and misuse of Personal Information under our control. No company or entity, including TechSoup Global, can fully eliminate the risks associated with gathering Personal Information on Worker Connect (please see our Terms of Use for more information). Caravan Studios has implemented technical and organizational measures to ensure the most complete protection of Personal Information processed through Worker Connect. However, because web-based data transmissions may in principle have security gaps, you are free to transfer Personal Information to us via alternative means, e.g. by telephone.

 

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Worker Connect account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Worker Connect account, please contact us following the instructions in the Contact Information section below.
 

What Information Does the Worker Connect Dashboard Collect and How Is It used?

​

There are two general categories of information we collect. We only collect and use your information to provide our services (e.g., for gaining access to the dashboard and its functionality, providing you with technical support, or providing you with updates to the service).

 

1. Information You Give to Us.

 

1.1 Information that is necessary for the use of Worker Connect (required; provided as necessity)

We require and collect the following personal information about you when you use Worker Connect. This information is necessary for the performance of a contract in which the data subject is a party and to allow us to comply with our legal obligations under the contract and more generally. The following information is required because without it, we may not be able to provide you with all the requested services:

​

• Information that you give us when you sign up for Worker Connect.  For example, when you sign up for Worker Connect, we’ll ask for Personal Information, like your name and email address.

• When you communicate with Caravan to provide additional contacts, or other information needed to assist you in utilizing Worker Connect, we collect information about your communication (such as your email address) and any information you choose to provide in order to use Worker Connect.

 

If you wish to use Worker Connect, we require the aforementioned information; if you do not want to provide this information, you should not use Worker Connect.

​

2. Information you to choose to give (optional; provided with consent)

​

• If you utilize the messaging functionality to communicate with workers on a specific project, for example to post messages, the information you send to workers will be seen by any and all workers who use the Worker Connect mobile application working on that project, and a record of the message will be saved by us on our sever.

• When you leave us feedback or request support, we will collect any information that is contained in your feedback or support request (including your email address).

 

Automatically Collected Information  

​

When you use Worker Connect, we automatically collect information, including Personal Information, about the services you use and how you use them. If collected, this information is necessary for our performance of a contract in which the data subject is a party and/or to allow us to comply with our legal obligations under the contract and more generally. Also, this information is necessary given our legitimate interest in being able to provide and improve the functionalities of Worker Connect.

​

• Usage Information. We collect information about your interactions with Worker Connect such as the pages or content you view, your searches, and other actions on Worker Connect.

• Log Data and Device Information. We automatically collect log data and device information when you access and use Worker Connect. That information includes, among other things: details about how you’ve used Worker Connect (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using Worker Connect.

• Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on Worker Connect, or engage others to track your behavior on our behalf. At any time, you may disable the usage of cookies through your browser settings, and thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via your browser.  If you deactivate the setting of cookies in your browser, it is possible that not all functions of our website(s) may be entirely used.

​

How We Use Information We Collect

 

We use, store, and process information, including Personal Information, about you to perform our services, provide and improve Worker Connect and comply with our legal obligations. It is not used for any additional purposes, such as to profile those who access Worker Connect.

 

1. Provide and Improve Worker Connect.  

​

• Enable you to access and use Worker Connect.

• Enable you to communicate with other users.

• Operate, protect, improve, and optimize Worker Connect, such as by performing analytics and conducting research.

• Provide customer service.

• Send you service or support messages, updates, security alerts, and account notifications.

 

We process this information given our legitimate interest in improving Worker Connect and our users’ and customers’ experience with it, and where it is necessary for the performance of the contract with you and/or a legal obligation. You can opt-out of receiving communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Worker Connect account.

​

2. Comply With Our Legal Obligations.

​

We may also use the information collected in order to:

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

• Conduct security investigations and risk assessments.

• Verify or authenticate information provided by you (such as to verify your authorization to act as an agent on behalf of an organization).

• Conduct checks against databases and other information sources, to the extent permitted by applicable laws.

• Resolve any disputes with any of our users or customers and enforce our agreements with third parties.

• Enforce our Terms of Use and other policies.

​

We process this information given our legitimate interest and legal obligation to protect Worker Connect, to measure the adequate performance of our contract with you, and to comply with applicable laws. TechSoup Global may process your information if it is necessary for legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

​

Sharing & Disclosure

​

Processing is lawful only if and to the extent one of the following applies:

​

1. With Your Consent.

​

Where you have provided consent, we share your information, including Personal Information, as described at the time of consent. 

 

2. Other Situations, such as pursuing a legitimate interest.

 

2.1. Profiles and other Public Information.

 

Worker Connect may let you publish information, including Personal Information, that is visible to the general public. Information you share publicly on Worker Connect may be indexed through third party search engines. If you change your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

 

2.2. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

 

TechSoup Global may disclose your information, including Personal Information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against TechSoup Global (including Caravan), (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Use or other agreements with our users and customers, or (v) to protect the rights, property or personal safety of TechSoup Global (including Caravan), its employees, its users, customers or members of the public.

Where appropriate, we may notify users and customers about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon TechSoup Global’s property, its users and customers and Worker Connect. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user or customer about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

 

2.3. Service Providers.

 

Since TechSoup Global is part of a global network, it conducts activities globally.  In doing so, TechSoup Global uses a variety of third parties to help us provide services related to Worker Connect. Service providers may be located inside or outside of the European Economic Area (“EEA”). The EEA unites the EU Member States and the three EEA EFTA States (Iceland, Liechtenstein, and Norway) into a market governed by the same basic rules (such as GDPR).  

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the TechSoup Global services through third party platforms and software tools (e.g., through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

If TechSoup Global needs to share your information, including Personal Information, with a service provider, in order to ensure the adequate performance of our contract with you, we are permitted to do so.

 

2.4. Business Transfers.

 

If TechSoup Global (including Caravan) undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, TechSoup Global will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

 

2.5. Aggregated Data.

​

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, insights about the sector, demographic profiling, marketing and advertising, and other business purposes. We may share this aggregated data with the public.

​

Data you receive about third parties

 

If you use Worker Connect, you might receive Personal Information from workers who have downloaded and utilized the Worker Connect mobile application, such as but not limited to the following examples of the same: nationality, languages spoken, employer name, and project(s) employed on. At this time, third party individuals are not identifiable by name or otherwise (i.e. contact information), except for the aforementioned characteristics.  Workers who have shared this information with TechSoup Global have permitted our disclosure with you, for the sole purpose of monitoring worker conditions and welfare on the designated project(s). Any other use is strictly prohibited.  TechSoup Global assumes no liability for the following: (i) the accuracy or reliability of the information; (ii) any reporting or disclosure requirements that might ensue; (iii) any other obligation or liability that is in any way related to the information provided.

 

Worker Connect may also contain links to third party websites or services, such as third party integrations, co-branded services, or wholly independent third parties (“Third Party Partners”). TechSoup Global doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, TechSoup Global, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

 

Your Rights

 

You may exercise any of the rights described in this section by sending an email to info@workerapp.org or privacy@techsoup.org. Please note that we may ask you to verify your identity before taking further action on your request.

​

1. Managing Your Information.

 

You may access and update some of your information through your account settings. You are responsible for keeping your Personal Information up-to-date.

 

2. Rectification of Inaccurate or Incomplete Information.

 

You have the right to ask us to correct inaccurate or incomplete Personal Information concerning you (and which you cannot update yourself within your TechSoup Account).

 

3. Data Access and Portability.

 

In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us. You may also be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

 

4. Data Retention and Erasure.

 

We generally retain your Personal Information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide Worker Connect to you, you can request that we erase your Personal Information and close your Worker Connect account. Please note that if you request the erasure of your Personal Information:

​

• We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Worker Connect account for fraud or safety reasons, we may retain certain information from that account to prevent that user or customer from opening a new Worker Connect account in the future.

• We may retain and use your Personal Information to the extent necessary to comply with our legal obligations. For example, TechSoup Global may keep some of your information for tax, legal reporting and auditing obligations.

• Information you have shared with others (e.g., forum postings) may continue to be publicly visible on Worker Connect, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

• Because we maintain Worker Connect to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.

​

5. Withdrawing Consent and Restriction of Processing.

​

Where you have expressly provided your consent to the processing of your Personal Information by TechSoup Global you may withdraw your consent at any time by changing your account settings or by sending a communication to TechSoup Global (or Caravan) specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (i) you contest the accuracy of your Personal Information; (ii) the processing is unlawful and you oppose the erasure of your Personal Information; (iii) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to the section immediately below (“Objection to Processing”) and pending the verification whether the legitimate grounds of TechSoup Global override your own.

​

6. Objection to Processing.

 

In some jurisdictions, applicable law may permit you to legally object to TechSoup Global’s processing. In these instances, you may require TechSoup Global not to process your Personal Information for specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing TechSoup Global will no longer process your Personal Information for these purposes unless we can demonstrate a legal basis for doing so or such processing is required for the establishment, exercise or defense of legal claims.

​

At any time, regardless of applicable law, you may object to us processing your Personal Information for direct marketing purposes. You may, at any time, ask TechSoup Global (or Caravan) to cease processing your data for these direct marketing purposes by sending an email to privacy@techsoup.org.

 

7. Lodging Complaints.

 

With respect to GDPR, you have the right to submit complaints about the data processing activities carried out by TechSoup Global before the Office of the Inspector General for the Protection of Personal Data; for complaints unrelated to GDPR, nothing in this Privacy Policy is intended to limit your right to file a complaint in the appropriate jurisdiction.

Operating Globally

​

To facilitate our global operations, TechSoup Global may transfer, store, and process your information within our family of public benefit organizations outside of the EU. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes and bases described in this Privacy Policy. Where we transfer store, and process your Personal Information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

 

EU Model Clauses.

 

If your information is shared with corporate affiliates or third party companies or service providers outside the EEA, we have, prior to sharing your information with such corporate affiliate or third party company or service provider, established the necessary means to ensure an adequate level of data protection. This agreement may incorporate the basis of the EU Model Clauses (a set of clauses issued by the European Commission).

​

Regarding Minors

​

Worker Connect is not designed for minors under the age of 13 and we do not intentionally gather Personal Information about visitors who are under the age of 13. If we learn that we have collected or received Personal Information from a child under 13, we will delete that information.

 

Contact Information

 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

​

Caravan Studios
435 Brannan Street, Suite 205
San Francisco, CA 94107

or by sending an email to info@workerapp.org.

 

Changes to Our Privacy Policy

 

This Privacy Policy is subject to periodic occasional revision. If we make material changes to this Privacy Policy, we will notify you through the website or, if you have provided your email address, by email. You agree that such amended Privacy Policy will be effective thirty (30) days after being posted or sent to you, and your continued access to Worker Connect after such time shall constitute your acceptance of the amended Privacy Policy.