Last Updated: October 14, 2019
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 (https://www.bestalliance.org) and/or Training Center website (https://www.best-training.org) (referred to herein, individually or collectively, as the “Site”), Products, and all Content associated with the Site (all collectively, the “Service”). Please review this Policy carefully, as well as our Terms of Use (“Terms”) governing your use of the Service, which can be viewed at https://www.bestalliance.org/ttc.html. By clicking “I Agree”, making a purchase through the Service, registering for an Account, or otherwise accessing or using the Service, 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 SERVICE, PURCHASE OR USE PRODUCTS, OR CLICK TO INDICATE THAT YOU AGREE TO THEM. Capitalized terms used but not defined herein have the definitions set forth in the Terms.
If you have any questions about this Policy, please contact us at info@bestalliance.org.
1. Information Collection
A. General. When you visit the Service, 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 using or accessing your Account or certain features of the Service, you may be asked to provide personally identifiable information. “Personally identifiable information” is information that can identify you directly or indirectly, 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 when using the Service. We may also collect information from your responses to offline documents, such as responses provided to questionnaires, surveys, forms, and other documents you provide to us. Use of information collected from these documents will be handled in accordance with this Policy.
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, and password selected by you.
D. User Comments. You may be permitted to post user comments in response to certain content, such as articles. We may save user comments, materials, or other content you post indefinitely.
E. Email Address Collection; BEST Newsletter. We may also collect personally identifiable information, such as your email address, when you use the Service, including when you create an Account, in order to send occasional updates and our BEST newsletter. In order to receive certain communications from us, such as 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 Service provides users the option to submit questions, feedback, or comments by filling out a form available under the “Contact Us” 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 identifiable 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 Questionnaires. We may provide you the opportunity to participate in questionnaires available through the Service. We will request certain personally identifiable information through those questionnaires. Use of such information will be in accordance with this Policy and any terms included with the questionnaire.
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 collection may include, but is not limited to, the Internet protocol (IP) address used to connect your computer and/or mobile device to the Internet; login; e-mail address; password; computer and connection information such as browser type, version, and time zone setting; operating system and platform; the date and time you access the Service; and the pages you visit. We collect this information for diagnostic purposes and to administer the Service.
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 gathering 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 Service; however, certain features of the Service 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 Service 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 Service. In doing so, we may share with these third parties non-personally identifiable information about users’ use of the Service. 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 or device 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 or device 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.
2. Information Use
A. Use of Personally Identifiable Information. We may use your personally identifiable information that you provide us, such as your name and 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 us or if you request more information regarding our Service, Products, and other 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 Service. We may also use personally identifiable information to resolve disputes; to make our Service safe, secure, and accurate; to detect and protect against errors, fraud, and criminal activity; to assist law enforcement; to enforce this Policy and the Terms; and for any other purpose described in this Policy or that we describe to you at the time of collection. When we work with companies and other organizations to provide services, such as providing access to certain training courses to employees or members of these organizations, we may share personally identifiable information with these organizations in relation to those services we provide.
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 Service, tracking users’ movements on the Service, and for management and improvement of the Service. 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 Service; to monitor aggregate metrics such as total number of visitors or pages viewed; or to track submissions in any interactive portion of the Service. 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.
3. Information Disclosure
A. Affiliated Entities or Service Providers. We will not sell or rent any of your personal information to third parties for marketing purposes. We may use third parties to help us operate the Service. For instance, we may use a third-party payment processing company to process payments, and we may use third-party service providers to provide advertising and analytics information for our Service. 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 Service, your comments will be made publicly available to anyone who visits that area of the Service. Other users or the general public may access, re-post, or use user comments that you make publicly available through the Service. Even if you remove or delete your comments, copies may remain in cached or archived areas of the Service. If you share content with Linked Sites, 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 share or 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 Service; 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 Service 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 Service may abuse or misuse your personal information.
4. 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 Service). Personally identifiable information collected by the Service 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.
5. Children’s Privacy
A. This Service 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 Service 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 Service, please notify us by going to the “Contact BEST” link at the bottom of the home page.
B. California Minors. While this Service is not intended for anyone under the age of 18, 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: (a) federal or state law requires us or a third party to maintain; (b) was not posted by you; (c) is anonymized so that you cannot be identified; (d) you do not follow our instructions for removing or requesting removal; or (e) 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.
6. 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 (if any) 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 sending us an email with “California Privacy Rights” in the subject line to info@bestalliance.org or by writing us at 1201 1st Ave South, Room 321, Seattle, WA 98134.
7. Linked Sites
The Service 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.
8. 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.
9. Changes to this Policy
We reserve the right to change this Policy at any time, in our sole discretion, upon notice to you. We may give notice by posting an updated Policy through the Service, sending you an email, or by other reasonable means. You can review the most current Policy at any time at http://bestalliance.org/privacy. When we change this Policy, we may require you to accept the updated Policy to continue using the Service. If you do not accept the updated Policy, you may continue using the Service under the Policy you previously accepted; however, certain parts of the Service may not be available to you. The updated Policy is binding on you on the effective date indicated at the top of this Policy.
10. 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 Us” link at the bottom of our homepage and using the form located there, or by contacting us at info@bestalliance.org.
