Privacy Policy

A4H’s (“A4H”, “we”, “us”, “our”) mission is to establish a global social media audience that can be used to promote prevention, awareness, and education as well as demand legislative and corporate change, all via partnerships (Alliances) with individuals and entities committed to end human trafficking.

In this privacy policy (the “Policy”), we describe A4H’s privacy and information practices and the rights and choices you have regarding the personal information that we collect about you, when you access or use our website, services or otherwise interact with us. 

OVERVIEW

We think transparency is important. In this overview, we summarize the personal information we collect and how we use it, which is further explained in our Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

Categories of personal information collected. Generally, we collect the following types of personal information:

• Name, contact information and other identifiers: direct identifiers such as a name, alias, user ID, username, account number, unique personal identifier, IP address and other online identifiers or unique identifiers, email address, phone number, address and other contact information, account name, government identifiers, or other similar identifiers.
• Records: personal information, such as name , contact information, and financial or payment information individuals provide to us. For example, this may include information collected when you purchase items through our shop or if you choose to make a donation to support our mission. Please note that we work with a third-party payment provider, who processes the transactions on our behalf.
• Usage data: browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our website and online services, and our marketing emails and online ads.
• Professional information: professional or employment-related information, such as current and former employer(s) and position(s), title and business contact information.
• Inferences:  inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify information and content that may be most relevant to you.

Purposes of use. In general, we may use and disclose personal information for the following purposes:

• Providing our services and related support (e.g., to fulfill an order you place through our shop)
• Communicating with you and responding to your requests
• Tailoring content and experiences
• Sending newsletters and other information and updates 
• Analyzing and improving our website and services
• In support of our general business operations
• Securing and protecting our assets and rights
• Complying with legal obligations

If you are a California resident, please review the Additional Information for California Residents section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.

• Information we collect
• How we use information
• How we disclose information
• Cookies and other tracking information
• Your choices and rights
• Security
• Retention
• Children
• Changes to this Privacy Policy
• Contact us
• Additional information for California Residents

SCOPE

This Policy explains how we process information that we collect from individuals that access our website, make purchases through our website, or communicate or engage with us about our mission and services (referenced herein as using the “Services”), i.e., the personal information we process as a “controller” or “business” under applicable privacy laws. 

Personal Information. In this Policy, the term “personal information” generally means any information that identifies, relates to, describes, or is reasonably capable of being associated, or reasonably linked or linkable with a particular individual. It does not include anonymous, aggregate or de-identified information that can no longer be linked to or used to identify a particular individual.

INFORMATION WE COLLECT

We may collect personal information directly from individuals, from third parties, or automatically related to the use of our website and Services. The personal information we collect and the sources from which we collect it, vary depending upon the circumstances.

Information We Collect from You. We may collect personal information directly from you, including:

• Name, usernames and contact details: we collect name, email address and contact information, preferences and other information from our website visitors and other interested individuals,. For example, if you wish to receive our newsletters, updates or read about our mission and projects, you are asked to submit a registration form. If you choose to make a donation for our cause, we may receive information about the donor name and amount (if you provided a name).
• Purchases: if you make a purchase through our online shop, we collect name, email address, contact information, including shipping information and payment and billing information. We work with a third-party service provider who handles the payment and fulfillment process on our behalf. 
• Communications, requests and support: if you contact us by email, mail, phone, contact us forms, or otherwise regarding the Services, we collect and maintain a record of your contact details, communications and our responses. If you call us, we may also record calls and maintain logs and records of those calls. 

Information We Collect from Third Parties. We may collect personal information about you from public sources or databases (such as demographic information, updated professional or contact details and similar information), from third party platforms related to your posts about or interactions with us on social media services, from advertising networks or analytics providers related to your viewing of interactions with our ads, marketing or other content and other third-party sources (including our partners and allies), in order to provide and enhance our mission and services.  

Information We Collect Automatically. We also may collect personal information about how you access, use and interact with our websites, applications and online service, such as information we collect automatically including cookies and pixel tags, IP address, app identifier, advertising ID, location information, browser type, device type, domain name, the website that led you to our website, the website to which you go after leaving our website, the dates and times you access our websites and online services, and the links you click and your other activities. We also may use pixels in HTML emails to understand if you read the emails we send to you. For more information, see the Cookies and Other Tracking Information section below.

HOW WE USE INFORMATION

The purposes for which we may process personal information vary depending upon the circumstances. 

Generally, A4H uses personal information for the following business and commercial purposes:

• Providing our services related support: to provide and operate our Services, such as for example to process and fulfill the orders you place through our Services.
• Communicating with you and responding to your requests: to communicate with you about your use of our website, to provide troubleshooting and technical support, respond to your inquiries, otherwise communicate with you, and for similar service and support purposes. 
• Analyzing and improving our website and services: to better understand how our websites are accessed and used, in order to administer, monitor, and improve our services, for our internal purposes, and for other research and analytical purposes. 
• Sending newsletters and other information and updates: to promote A4H’s products and services and for direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you. 
• Tailoring content experiences: to tailor content we may send or display on the website or otherwise, to offer location customization and personalized help and instructions, and to managing our information, awareness and promotional campaigns . 
• In support of our general business operations: related to the administration of our general business, operational, accounting, recordkeeping and legal functions. For example, as part of any merger, sale, transfer of assets, acquisition, financing and/or restructuring, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law. 
• Securing and protecting assets and rights: to protect the services and our business operations, to prevent, detect and investigate fraud, misuse, harassment or other types of unlawful activities; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy and our applicable agreements and terms of use. 
• Complying with legal obligations: to comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. 

Aggregate and anonymous data. We may also create and use aggregate, anonymous and de-identified data to improve and develop our business and services, and for similar research and analytics purposes. We may use automated processes, artificial intelligence, and machine learning, to analyze data, which helps us improve our services and identify fraud patterns.

HOW WE DISCLOSE INFORMATION

We may share or disclose personal information that we collect as follows:

• Subsidiaries and affiliates: with our subsidiary and affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); their use and disclosure of such personal information is subject to this Policy.
• Vendors and providers: with our third-party service providers who use this information to perform services on our behalf, such as hosting and cloud storage providers, payment providers, auditors, advisors, consultants, customer service and/or support providers. 
• Legal compliance: in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. 
• Business transfers: as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
• Protection of rights: where we believe necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, to protect the rights, property or safety of A4H, our affiliates, prospective customers and/or others, and/or as evidence in litigation in which we are involved. 

Aggregated and De-identified Data. We may share aggregate or de-identified data with third parties for research, marketing, advertising, analytics and/or other purposes.

COOKIES AND OTHER TRACKING INFORMATION

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the website and online services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our website and services are used, track bugs and errors, provide and improve our services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, to personalize content, and for analytics purposes.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website, while others allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Parts of our website may not work properly if you disable cookies.

Pixel Tags. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Managing Your Cookie Preferences. You can review and manage your cookie preferences for our websites and opt out of certain cookies by adjusting your cookie settings via our cookie preference manager and/or your browser settings (as explained below).

Please note, that your preferences are applied on a browser and device basis. So, you will need to set your cookie preferences for each browser and device you use to access certain of our websites. Further, if you subsequently delete cookies, your preferences may be lost and need to be reset. 

Cookie Preference Manager.  Review and manage your cookie settings via the blue button on the bottom left of a4h.org 

Browser Settings. You can also block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our website may not be available or function properly if you block or disable cookies. Please note that your cookie preferences are applied on a browser and device basis. So, you will need to set your cookie preferences for each browser and device you use to access our website.

Interest-Based Advertising. We may work with third party ad networks, analytics companies, measurement services and others (“third party ad companies”) to help us manage our advertising on third party sites and services. We and these third party ad companies may use cookies, pixels tags, and other tools to collect activity information on our website (as well as on third party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent; we and these third party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. In addition, these third parties may combine the information collected from us and our website with information collected about you from third-party sites, apps, and services, in order to make inferences about you and your interests, to better tailor advertising and content to you across multiple sites, apps, and services and to collect associated metrics. For more information about third party ad networks and how to opt out of interest-based ads from many ad networks go to www.aboutads.info.

Custom Audiences.  In addition, we may share certain hashed customer list information, such as email address, (“Custom Lists”) with third parties—such as Facebook, LinkedIn and Google—so that we can better target ads and content to our users and others with similar interests within their services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.

YOUR CHOICES AND RIGHTS

Access, Amend and Correct. If you wish to access or amend certain personal information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request to privacy@A4H.org. We will review your request and make reasonable efforts to respond to it as soon as practicable. We may ask you for additional information so that we can confirm your identity.

Direct Marketing. You may always opt-out of direct marketing emails. If you would like to unsubscribe from our email subscriptions or otherwise change your email preferences with A4H, please follow the instructions in any of our promotional emails that we send to you, e.g., by clicking the unsubscribe link provided therein. Please note, that we may continue to send you transactional or service-related communications, such as purchase and order confirmations, service announcements and administrative messages. 

Additional Information for California Residents. In the section Additional Information for California below, we provide additional information as required under California privacy law.  If you are a resident of California, you should review that section for more information regarding your rights under California privacy laws. 

SECURITY

We have implemented administrative, physical, personnel, and technical safeguards designed to protect the personal information we collect or hold on behalf of customers from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

RETENTION

Generally, we retain your personal information for as long as necessary to fulfill the purposes for which we collected it or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

CHILDREN

Our Services are not targeted to minors under the age of sixteen (16) and we do not knowingly or specifically collect information about minors under the age of 16. If you believe we have unintentionally collected such information, please notify us as set out in the Contact Us section below.

CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, for example to reflect new privacy law requirements or changes in our privacy practice. If we make changes to this Policy, we will post a new version of this Policy on our website. If the changes materially affect the way we collect, use, disclose or otherwise process your personal information, we will endeavor to notify you in advance of such change(s), such as by sending a notice to the primary email address associated with your account or by posting a notice on the website. We encourage you to periodically check back and review this Policy for the latest updates.

CONTACT US

If you have any questions about this policy, please feel free to contact us at privacy@A4H.org.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

In this section, we provide additional information for California residents, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA. While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Effective Date above).

Categories of personal information collected and disclosed. The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the How We Use Information and the How We Disclose Information sections above.

Personal Information Collected

Categories	Description	Categories of Third Parties to Whom We May Disclose this Information
Identifiers	Includes direct identifiers, such as name, alias user ID, username, account number; email address, phone number, address and other contact information; IP address and other online identifiers; and other similar identifiers.	• partners  • affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement • data analytics providers • internet service providers • operating systems and platforms
Records	Includes personal information, such as name, account name, contact information and financial or payment information. For example, this may include information collected when an individual purchases products through our websites or donates to support our mission.	• partners  • affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement
Commercial Information	Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	• affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement • data analytics providers • internet service providers • operating systems and platforms
Usage Data	Includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our websites, mobile apps and other Services, and our marketing emails and online promotions or ads.	• affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement • data analytics providers • internet service providers • operating systems and platforms
Audio, video and electronic data	Includes audio, electronic, visual, or similar information such as, photographs and images (e.g., that you provide us) and call recordings (e.g., of customer support calls).	• affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement
Professional information	Includes professional and employment-related information such as business contact information and professional memberships.	• affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement
Inferences	Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities or aptitudes. For example, we may analyze personal information in order to identify information and content that may be most relevant to. you	• our affiliates and subsidiaries  • service providers • advisors and agents • government entities and law enforcement • analytics providers

Sources of personal information. As further described in the section Information we collect above, we may collect personal information from the following sources:

• directly from you 
• our parent company, affiliates and subsidiaries
• partner and allied organizations 
• data analytics providers
• public records
• social media networks
• service providers
• advisors and agents

Do We “Sell” Personal Information? The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation from such third parties, we do disclose or make available certain categories of personal information to third parties in order to receive certain services or benefits from them, such as when we make browsing history available to third-party ad companies (through third-party tags on our website) in order to improve and measure our ad campaigns and reach individuals with more relevant ads and content. As defined by the CCPA, we may “sell” Identifiers and Usage Data to third-party advertising networks, analytics providers, and social networks.

California residents’ rights.  In general, California residents have the following rights with respect to their personal information:

• Do-not-sell (opt-out): to opt-out of our sale of their personal information. We do not sell personal information about California consumers, including those we have actual knowledge are younger than sixteen (16).
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions. 
• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
  • categories of personal information collected;
  • categories of sources of personal information;
  • categories of personal information about them we have disclosed for a business purpose or sold;
  • categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
  • the business or commercial purposes for collecting or selling their personal information; and
  • a copy of the specific pieces of personal information we have collected about them.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA. 

Submitting CCPA requests. California residents may submit CCPA requests to know (access) and requests to delete their personal information by email at privacy@A4H.org.  You can opt-out of sales of your personal information, as explained above, through our cookie preference manager by pushing the blue button located on the bottom left hand side of a4h.org

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must email us with any requested information (or otherwise provide us with this information to verify your request.  In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us through the above listed method; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.  

For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.