Privacy Policy

Your information privacy is extremely important to us. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Omidyar Group website (“Site”) and other services offered by The Omidyar Group. (“Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services. The Site and Services are provided by The Omidyar Group (“Company” “we” “our” “us”).

By using the site or services, you are consenting to this privacy policy. Please read it carefully.

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1. Managing Your Information Preferences

You are able to opt out of receiving marketing e-mails from us by unsubscribing to our emails. If you have questions or concerns regarding this Privacy Policy, please e-mail us at inquiries@omidyargroup.com

2. Information We Collect

Personal Information

We collect information that personally identifies you, such as your name, address, e-mail, phone number, and other personally identifiable information that you choose to provide us with (“Personal Information”).

Usage Data and Site Activity

We automatically collect information regarding the actions you take on the Site (“Usage Data”). For example, each time you use the Site we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. We use this information to help us understand how people use the Site and Services, and to enhance the services we offer.

Cookies and Anonymous Identifiers

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other anonymous identifiers to analyze use of and improve the Site and Services and as described in the Online Tracking Section of this Privacy Policy. We do not use cookies to collect Personal Information. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers or Select Partners (each defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

What Cookies We Use?

We do not place cookies until you elect to continue using the Services after our cookie banner displays. We use performance cookies, which allow us to count visits and traffic sources, so we can measure and improve the performance of the Services. They help us know which pages are the most and least popular and see how visitors move around the Site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited the Services.

You can also learn more about cookies and set cookies preferences from allaboutcookies.org, www.aboutads.info/choices, and www.networkadvertising.org.

How we Deploy Cookies

Third-party cookies. We use cookies issued by third parties to display content from third parties. The third party suppliers are responsible for the cookies they set on the Services. If you want further information please go to the website for the relevant third party.

Our Legal Basis for Processing Information Collected by Cookies

The information we obtain from our use of cookies may contain your personal data but only where you voluntarily provide it (e.g., by completing an online form or entering your email address into a subscriber box) or where you purchase goods or services from us. We will process your personal data for strictly necessary and performance cookies based on our legitimate interests. For functional cookies, we will process your personal data based on your consent. For more information about how we process your personal information, obtain consent and how you may withdraw consent, please see Section 10 of this Policy.

By continuing to browse on the Services you consent to us deploying cookies as described in this Policy. If you do not wish to accept cookies from the Services, or would like to stop cookies being stored on your device in the future, see opt out information in the chart below.

If you have any questions about our use of cookies or other technologies or this Policy, you may email us at inquiries@omidyargroup.com.

*PARTY SETTING COOKIE (E.G.,* THE OMIDYAR GROUP OR PARTNER)**	TYPE OF COOKIE	PURPOSE/ FUNCTIONALITY	MORE INFORMATION AND HOW TO ADJUST SPECIFIC COOKIES’ SETTINGS
Google Analytics		Google Analytics is a site analytics tool that provides insight on user behavior. These cookies are used to better understand how users are using the Site so we can improve and optimize the Site, creating the best possible experience for users.	You can find out how to opt out of these cookies here. This link will open in a new window. The Omidyar Group is not responsible for the content of external websites.

3. Service Providers

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved.

4. Online Tracking

Our systems do not recognize browser “Do Not Track” signals, but several of our Service Providers and Select Partners who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.

5. Other Transfers

We may share Usage Data with businesses controlling, controlled by, or under common control with our Company. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Usage Data in connection with such transaction.

6. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Usage Data to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

7. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

8. Links

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

9. Children’s Privacy

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publically posted on the Site or Services by e-mailing us at inquiries@omidyargroup.com. Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.

10. Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location.

a. Additional Note for EU Users — Your Rights and Choices

The data controller for the Site and Services is:

The Omidyar Group
4348 Waialae Ave #368
Honolulu, HI 96816

Under EU data protection legislation, “Personal Information” includes a broad amount of information, including any information that can be used to identify, directly or indirectly, in particular by reference to an identifier such as an IP address, location data, and an online identifier. Since we may collect some if this type of information when we collect Usage Data, you may have additional protections under EU data protection legislation, if you reside in the EU. Under EU data protection legislation, we are only permitted to use your Personal Information if we have a legal basis for doing so. In addition to your consent, we rely on the following legal bases to use your information:

Where we need to comply with a legal obligation
Where the processing is necessary for us to carry out activities for which it is in The Omidyar Group’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our company and measure the reach and effectiveness of our company—this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively—this will include: processing for website content improvement; and processing for a statistical analysis of users’ behavior.

In more limited circumstances we may also rely on the following legal bases:

Where we need to protect your interests (or someone else’s interests)
Where it is needed in the public interest or for official purposes

You have a number of rights under EU data protection legislation in relation to your Personal Information, these include the right to:

Be informed about how we use your Personal Information
Obtain access to your Personal Information that we hold
Request that your Personal Information is corrected if you believe it is incorrect, incomplete or inaccurate
Request that we erase your Personal Information in the following circumstances:
- If we are continuing to process Personal Information beyond the period when it is necessary to do so for the purpose for which it was originally collected
- If we are relying on consent as the legal basis for processing and you withdraw consent
- If we are relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
- If the Personal Information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
- If it is necessary to delete the Personal Information to comply with a legal obligation

Ask us to restrict our data processing activities where you consider that:
- Personal Information is inaccurate
- our processing of your Personal Information is unlawful
- where we no longer need the Personal Information but you require us to keep it to enable you to establish, exercise or defend a legal claim
- where you have raised an objection to our use of your Personal Information
Request a copy of certain Personal Information that you have provided to us in a commonly used electronic format.
Object to our processing of your Personal Information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your Personal Information
Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you wish to exercise any of your above rights, please reach out to us by emailing us at: inquries@omidyargroup.com

11. Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

Please print a copy of this privacy policy for you records and please check the Site frequently for any changes.