Introduction
This privacy policy (this “Privacy Policy”), including GDPR compliance, sets forth how International Project Noosphere For Integrative Medicine Inc. doing business as Project Noosphere (“Project Noosphere”, “we”, “us”, or “our”) collects, processes, stores, and discloses your personal data if you visit or use the website at www.project noosphere.com (the “Website”), our mobile applications, and any of our services (collectively, “Services”) or otherwise provide personal data to us. PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE TO ITS TERMS, DO NOT VISIT OR USE THE WEBSITE AND/OR THE SERVICES.
WHAT IS GDPR?
With users in nearly every country in the world, we adhere to the General Data Protection Regulation (GDPR). The GDPR expands the privacy rights granted to individuals located in the European Union, Iceland, Liechtenstein or Norway (collectively, the “EU”) and requires companies that collect and process personal data of these individuals to comply with certain privacy regulations. Personal data is any information related directly or indirectly to a natural person. The GDPR applies to companies that collect and process the personal data of individuals in the EU and have a presence in the EU (e.g. offices or establishments), as well as companies that do not have any presence in the EU but target individuals in the EU (e.g. by offering goods or services to such individuals) or monitor the behavior of individuals in the EU. The GDPR is designed to strengthen the security and protection of personal data of individuals in the EU, as well as provide businesses with a structured framework on how to collect, process, use, and share such personal data.
PERSONAL DATA WE COLLECT
Project Noosphere collects and uses your personal data to operate the Website and Services, as well as to deliver any services, or complete any sales transactions, you request.
We collect, process, store and use your personal data, including your name, email address, physical address, and phone number, when you register as a member with Project Noosphere or fill out our forms for more information.
Project Noosphere may also use your personal data to inform you of other products or services available from Project Noosphere. We may also contact you via surveys to conduct research about your opinion of current services or potential new services that may be offered.
When you log in to Project Noosphere, the Website and Services allows you to “set your intention” by collecting and disclosing your name (or an alias) and your location on a map to other members. By registering with Project Noosphere and using the Website
and Services, you hereby expressly agree to the collection and disclosure of your name (or an alias) and your location on the map.
When you contact us by email or mail, the email or mail address you provide may be used to send you information, respond to inquiries, and/or other requests or questions. We also may keep a record of the correspondence and may also record any telephone conversation we have with you.
All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, or we suspect or identify fraud, we will record this.
DATA WE AUTOMATICALLY COLLECT
When you visit the Website and/or the Services, we, or our third-party vendors, automatically collect and store information about your device and your activities. This information may include (without limitation) (a) your computer or other device’s unique ID number; (b) technical information about your device such as type of device, web browser, IP address or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing activities and patterns. We may use your IP address to identify the general geographic area from which you are accessing the Website or Services. We collect this information using cookies in accordance with the Cookie section of this Privacy Policy and we use the information we collect on an anonymous basis to improve the Website and Services, as well as for analytical and research purposes. We may also collect other information as described in this Privacy Policy.
We also allow advertisers and advertising networks to collect information about your computer or mobile device, activities, and geographic location to enable them to display targeted ads to you and provide us with anonymous information about our users’ behavior. Again, this takes place through the use of cookies in accordance with the Cookie section of this Privacy Policy.
WHAT DO WE USE YOUR INFORMATION FOR?
We use the information we gather from you for systems administration purposes, abuse prevention, and to track user trends, and for the other purposes described in this Privacy Policy.
MARKETING COMMUNICATIONS
By signing up with Project Noosphere and opting in to receive marketing communications from us, you consent to the processing of your data to send you such communications, which may include newsletters, blog posts, surveys and information about new events. We retain a record of your consent.
You can opt out of receiving marketing communications by contacting us at support@projectnoosphere.com or clicking “unsubscribe” from a marketing email. If you unsubscribe to marketing communications, it may take up to five (5) business days for your new preferences to take effect.
LAWFUL PROCESSING OF YOUR PERSONAL DATA
We collect and use your personal data for the purposes described in this Privacy Policy on the basis of our legitimate interests (for example, providing, improving and customizing our offerings, administration of our operations or for website analytics); to process transactions requested by you and meet our legal, regulatory and contractual obligations (for example, meeting our obligations and enforcing our legal rights, shipping items to you that you purchase, providing required information to tax authorities or contacting you with requested information relating to Project Noosphere); or on the basis of your consent, where applicable.
WHO DO WE SHARE YOUR DATA WITH?
We share your personal data with third-parties in the ways described in this Privacy Policy. Project Noosphere does not sell, rent or lease to third-parties any personal data it collects.
Project Noosphere may share personal data with our third-party vendors to help perform statistical analysis, send you email or postal mail, or provide you with customer support. We may also share your personal data with third-party service providers, sub-contractors, and agents that we appoint to perform services on our behalf and in accordance with our instructions, including (but not limited to) payment providers, email communication providers, IT service providers, accountants, auditors and lawyers. All such third-parties are prohibited from using your personal data except to provide their contracted services to Project Noosphere, and they are required to maintain the confidentiality of your personal data.
Project Noosphere may disclose your personal data to third-parties when we believe that doing so is necessary or appropriate to satisfy any applicable law, regulation, legal process or governmental request; detect, prevent or otherwise address fraud, security, or technical issues; or protect our rights, property, or safety or the rights, property, or safety of our users or third-parties.
WHERE WE HOLD AND PROCESS YOUR PERSONAL DATA
Some or all of your personal data may be stored outside of the European Union (the EU), including for example, if our email server is located outside the EU or if any of our service providers or their servers are based outside of the EU. We shall only transfer your personal data to organizations that have provided adequate safeguards with respect to your personal data.
YOUR RIGHTS
In certain cases, you may have the right to obtain a copy of the personal data we collect in an easily accessible format, and to require us to
- correct or update the personal data if it is inaccurate or incomplete;
- restrict or limit the ways in which we use your personal data;
- object to the processing of your personal data; and
- request the deletion of your personal data.
To exercise these or any other rights you may have under applicable laws, please contact us at support@projectnoosphere.com. Because we want to avoid taking action regarding your personal data at the direction of someone other than you, we may ask you for information verifying your identity.
We will respond to your request without undue delay and in any event within one (1) month of receipt of the request, which can be extended by two further months where necessary, taking into account the complexity and number of the requests.
We reserve the right to charge a reasonable administrative fee, taking into account the administrative costs of providing the information or communication or taking the action requested, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character.
If you withdraw your consent to the collection, storage, use or sharing of your personal data for the purposes set out in this Privacy Policy, you may lose access to all (or some of) the Website and Services.
Please note that, in certain cases, we may continue to process your personal data after you have withdrawn consent and requested that we delete your personal data if we have a legal basis to do so. For example, we may retain certain data if we need it to comply with an independent legal obligation, if we still need the data for the lawful purposes for which it was obtained, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.
If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority).
RETENTION
We will retain your personal data for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
Where we are processing personal data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest,
taking into account the fundamental interests and the rights and freedoms of the data subjects.
Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities, to which you consented, subject to your right, under certain circumstances, to have certain of your personal data erased.
Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (“CCPA”)
Project Noosphere (1) does not have annual gross revenues in excess of twenty-five million dollars, (2) does not buy, receive, sell, or share for commercial purposes, alone or in combination, the personal information of 50,000 or more California consumers, households, or devices, and (3) does not derive fifty percent or more of its annual revenues from selling California consumers’ personal information. As such, Project Noosphere and the Website and the Services are not subject to the California Consumer Privacy Act of 2018.
COOKIES
The Website uses cookies as is common practice with almost all websites. Cookies are tiny files that are downloaded to your computer, to improve your experience. This page describes what information cookies gather, how we use them and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored; however this may downgrade or ‘break’ certain elements of the Website and Services’ functionality.
For more general information on cookies see the Wikipedia article on HTTP Cookies.
HOW WE USE COOKIES
We use cookies for a variety of reasons, including (but not limited to) understanding and saving your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better website experiences and tools in the future. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to the Website. It is recommended that you leave on all cookies if you are unsure whether you need them or not in case they are used to provide a service that you use.
DISABLING COOKIES
You can disable cookies by adjusting the settings on your web browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of the Website and many other websites that you visit. Therefore it is recommended that you do not disable cookies.
THE COOKIES WE SET
When you submit personal data to us through a form, such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
In some special cases, we also use cookies provided by our third-party vendors. The following section details which third-party cookies you might encounter through the Website or Services.
The Website and Services uses Google Analytics, which is one of the most widespread and trusted analytics solution on the web, to help us understand how you use the Website and Services and ways in which can improve your user experience. These cookies may track things, such as how long you spend on the Website and Services and the pages that you visit, so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.
From time to time we test new features and make subtle changes to the way that the Website and Services are delivered. When we are still testing new features, cookies may be used to ensure that you receive a consistent experience on the Website and Services while ensuring we understand which optimizations our users appreciate the most.
Cookies allow us to monitor our advertising to make business predictions and ensure the best possible user experience.
We also use social media buttons and/or plugins on the Website and Services that allow you to connect with your social networks in various ways. For these to buttons and/or plugins work, the following social media websites including; Facebook, Instagram, YouTube, and will set cookies through the Website and Services which may be used to enhance your profile on their website or contribute to the data they hold for various purposes outlined in their respective privacy policies.
SECURITY
We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL technology.
Where we have given, or you have chosen a user name and password, you are solely responsible for keeping this user name and password confidential.
You acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we do not represent or warrant that your personal data will always remain completely secure.
The Website and Services may enable users to submit their own user content. Unless otherwise indicated, please remember that any personal data you submit or post as user content can become public information. You should exercise caution when disclosing your personal, financial or other information in such submissions or posts. You acknowledge and agree that you disclose such information at your own and sole risk. We cannot prevent others from using that information in a manner that may violate this Privacy Policy, applicable law or your personal privacy and safety. We are not responsible or liable for any user content you submit or post or for how such content may be used by others.
MORE INFORMATION
If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as closely as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
We may update and change the terms of this Privacy Policy from time to time without notice. You are responsible for regularly reviewing this Privacy Policy, so that you are aware of any updates or changes. By using the Website and Services, you are deemed to have accepted the Privacy Policy in effect at the time of your use.
CONTACT INFORMATION
If you have questions or comments regarding this Privacy Policy. Please contact Project Noosphere at:
Project Noosphere
735 Bishop Street, Suite-200
Honolulu, Hawaii 96813
Toll Free: 877-888-8970
International: 847-235-4826
Fax: 818-864-3388
Email: support@projectnoosphere.com
Effective as of March 18, 2020