1. Terms and Definitions
When we say “we”, “us”, “ours” we are referring to The Comrade Cooperative or its legally owned properties. “Personal Information” means any information that identifies or can be used to identify a person, directly or indirectly, including, but not limited to, first and last name, date of birth, e-mail address, gender, occupation or other demographic information.
- Website Visitor/User is every person who loads our website in their browser or visits different sections or pages of the website (either by entering the URL or following a hyperlink from another website or source).
- Type of data that may be processed: cookies stored in the user’s browser; City or country location based on the IP address of the device which is part of the data that each website receives; Statistical data on the users interactions on the website; Data on the browser or device used to browse the website.
- Purpose of use: Providing basic and support functions for the proper and efficient functioning of the website; Statistical reports on how and when the website is used.
- Storage Lifespan: Until the expiration of each cookie carrying the corresponding information (from one browsing session to up to a year) or until the user deletes the cookie directly from its browser and/or device.
- E-mail subscriber is each person who has consented to receive regular, unprompted e-mails from us. The e-mail may be sent via third-party e-mail services.
- Type of data that may be processed: Names, E-mail address, and Subscription preferences.
- Purpose of use: Providing the basis for serving e-mail newsletters and updates for which the person has given consent.
- Storage lifespan: Up to one month after an unsubscription has occurred.
- Legal reason: Consent for receiving an e-mail newsletter
Where we require your consent to process your Personal Information, we will ask for your consent to the collection, use, and disclosure of your Personal Information as described further below.
4. Information We Collect:
- Information you voluntarily provide to us: When you send us an e-mail or a message or contact us in any other way, you are voluntarily giving us information, some of which is collected. That information may include either your name, e-mail address, phone number etc. By giving us this information, you consent to this information being collected, used, disclosed, transferred and stored by us for future reference on the history of our communication.
- Statistical information we collect automatically: When you browse our websites, we may collect information about your visit and the way you browsed our websites. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our websites. The above information is gathered as statistical data and is anonymous.
- Information we store as a contact list: When you communicate with us via the contact forms on our website, subscribe to a newsletter or other means we will store Personal Information as a record of our communication. This information may include name, e-mail, city, e-mail subscriber preferences. The above information is gathered when an explicit consent is given within the corresponding forms. In case of recruitment campaigns, we may also gather a CV if you decide to upload one for the duration of the recruitment campaign.
- Information from your use of our websites or email campaigns: If you are in our contact list we may receive information about how and when you interact with our e-mail campaigns, store it in log files and link it to other information we collect about you. This information may include, for example, time, date and actions you have taken within the website or an e-mail campaign. This type of information helps us to improve our website and the content of our e-mail campaigns, for both you and for all of our users.
- Web beacons: The third-party e-mail service providers we use (MailChimp) implement web beacons in our e-mails. When we send e-mails to an E-mail Subscriber, we track who opened the e-mails and who clicked the links. This allows us to measure the performance of our e-mail campaigns.
5. Your rights
If we collected or stored your Personal Information you have the following rights you can exercise by contacting us at contact(@)comradecoop.com.
- The right of access – you have the right to ask us what Personal Information we have on you and if we do, to access that information.
- The right to rectification – If you find your Personal Information to be incorrect or incomplete you have the right to request it to be changed accordingly.
- The right to erasure – (right to be forgotten): Under special circumstances (such as your Personal Information being misused or you have withdrawn your consent for its use or storage and there is no further reason for using that data) you have the right to contact us to erase that Personal Information.
- The right to restrict processing – Under special circumstances where you have doubts about the correctness of your Personal Information or you disagree with the legitimate use of your information you have the right to request from us to not use that information until a solution is found.
- The right to object – If you have doubts about the legitimate purpose for using your Personal Information you have the right to object against such use, presenting the arguments for your suspicions.
- The right to data portability – If your Personal Information is collected with your consent via automated methods you have the right to ask us to send you your data in a machine-readable format in order to transfer them to another data controller.
6. Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
- To promote important milestones from our company via e-mail campaigns. You can stop receiving our e-mails by following the unsubscribe instructions included in every e-mail we send.
- To send you informational and promotional content through our social media channels in accordance with your preferences.
- To protect the rights and safety of our partners as well as our own.
- To meet legal requirements and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide support for an inquiry. This includes our use of the data that our partners, users and subscribers provide us in order to communicate with them efficiently. This also includes, for example, aggregating information from your previous communication with us and use of the websites. This might also include sharing your information or the information you provide us with third-party services such as Email management software (we use MailChimp) or online survey forms (Typeform). Our third party service providers are fully compliant with the GDPR directives and are certified under the EU-US Privacy Shield.
7. Public Information and Third Party Websites
- Social media platforms and widgets. Our websites include some social media features (like the Facebook Share button). In order to function properly they may set a cookie and in order to use them, you may share with them information about your IP address and which page you are visiting on our Websites. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. Your interactions with those platforms are governed by the privacy policies of the companies that provide them.
- Links to third-party websites. In some page sections or blog articles on our Websites may include links to other websites. Their privacy policies will be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies.
8. Third Parties
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
- Service Providers. Sometimes, we share your information with our third-party Service Providers, who help us provide and support our business. We work with third-parties which are fully compliant with the GDPR directives and are certified under the EU-US Privacy Shield.
9. Notice of Breach of Security
In case of a security breach affecting your data then we will notify you personally or release a general statement with details. Later we will also release a report on the actions we took.
10. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access taking into account the risks involved in the processing of Personal Information.
You have the right to an individual access to Personal Information we might have collected from you. We can provide that information to you within 30 days of the request. You can request to access, correct, amend or delete information we hold about you by writing to us at contact(@)comradecoop.com. Unless it is prohibited by law, upon request from you, we will remove any Personal Information we might have collected from you.
If you have any questions or comments, or if you want to delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our e-mail contact(@)comradecoop.com to send us a message.
Last edited: 22 May 2018