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Wednesday, 07 April 2010 14:17

European Centre for Living Technology ("ECLT," "we," "us") is concerned about online privacy issues and wants you to be familiar with how we collect, use and disclose your Personally Identifiable Information (as defined below). This Privacy Policy (the "Policy") describes our practices in connection with Personally Identifiable Information that we collect through our websites located at www.ecltech.org (the "Site"). This Policy does not address our practices regarding information that we collect through any website, or by any other means, other than through the Site.

The Site is made available by ECLT to this Policy. We reserve the right to update or make changes to this Policy from time to time in our sole discretion without prior notice, which changes we may provide to you by any reasonable means, including without limitation, by posting the revised version of this Policy on the Site. You can determine when this Policy was last revised by referring to the "LAST UPDATED" legend at the top of this Policy. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect. By using the Site, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site.

 

1. What Types of Information Does The European Centre for Living Technology Collect From Me?

ECLT gathers two basic types of information through the Site: "Personally Identifiable Information" (or "PII") and "Non-Personally Identifiable Information" (or "Non-PII"). Personally Identifiable Information is information that identifies a person as an individual. Non-Personally Identifiable Information is aggregated information, demographic information and any other information that does not reveal a person's specific identity. An IP Address is the Internet Protocol address of the computer that you are using.

  1. Personally Identifiable Information. You do not have to provide PII to use the Site. However, in order for you to take advantage of particular opportunities provided through the Site (for example, to sign up for a newsletter), we may require that you furnish PII. We collect PII from you through the Site, such as your name, email address, only when you voluntarily provide it to us.
  2. Non-Personally Identifiable Information. When you visit and interact with the Site, ECLT and third parties with whom ECLT has contracted to provide services to ECLT may collect Non-PII (for example, a catalog of the Site pages you visit). Non-PII is generally collected through the Site from four different sources: (i) environmental variables, (ii) cookies, and (iii) information that you voluntarily provide to us.
    1. Environmental Variables. We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most websites, and can be used to optimize your experience on the Site.
    2. Cookies. We and our service providers may use "cookies" on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer.
    3. Information That You Voluntarily Provide. ECLT also collects Non-PII (e.g., your interests, your geographic location, etc.) when you voluntarily provide such information to us. Such information constitutes Non-PII because, unless combined with PII, it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Policy.
  3. IP Addresses. When you visit and interact with the Sites, ECLT and third parties with whom ECLT has contracted to provide services to ECLT may collect IP Addresses. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Sites, along with the time(s) of your visit(s) and the page(s) that you visited.

 

2. How Does ECLT Use Information Collected From Me?

  1. Personally Identifiable Information. We may use PII in the following ways:
    1. Fulfillment of Requests. ECLT may use PII about you to fulfill the purpose for which such PII was provided (e.g., to send newsletters to you).
    2. Administrative Communications. From time to time, in our sole discretion, we may use PII about you to send to you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
    3. Other Communications. From time to time, we may use PII about you to inform you of information that we believe may be of interest to you.
    4. Internal Business Purposes. We may also use PII about you for our internal business purposes, such as data analysis, audits and so forth.
  2. Non-Personally Identifiable Information. Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non PII, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose.

    In some instances, we may combine Non-PII with PII (such as combining your name with your geographic location). If we do combine any Non-PII with PII, the combined information will be treated by us as PII hereunder as long as it is so combined.

 

3. How Is Personally Identifiable Information Disclosed?

  1. Law enforcement; emergencies; compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose PII about you to others as we believe to be appropriate (a) under applicable law; (b) to comply with legal process; (c) to respond to governmental requests; (d) to enforce our Terms of Service; (e) to protect our operations or those of any Affiliated Entities; (f) to protect the rights, privacy, safety or property of ECLT, the Affiliated Entities, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose PII about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.

 

4. Other Important Notices Regarding Our Privacy Practices.

  1. Third Party Sites. The Site may contain links to third party websites. These linked sites (including without limitation the websites of Affiliated Entities) are not under ECLT's control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by ECLT. If you provide any PII through any such third party website, your transaction will occur on such third party's website (not the Site) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, THE AFFILIATED ENTITIES.
  2. Security. We seek to have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect PII about you, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. You acknowledge and agree that any information you transmit through the Site or upload for storage in connection with the Site is so transmitted or stored at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with Section 4.h ("Contacting Us") below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
  3. Opt-Out. If you do not wish to receive newsletters from us, you may opt-out of receiving such newsletters by following the unsubscribe instructions at the bottom of such newsletter.

    We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove PII about you from the databases of Affiliated Entities with which we have already shared PII about you (i.e., to which we have already provided PII about you as of the date on which we implement your opt-out request).

  4. Changing or Suppressing PII about you. To the extent the laws of your country entitle you to review, correct, update or suppress PII about you that has been previously provided to us, you may exercise this right by emailing us at This e-mail address is being protected from spambots. You need JavaScript enabled to view it For your protection, we will only implement such requests with respect to the PII associated with the particular e-mail address that you use to send us your request, and we may need to verify your identity before implementing your request.

    In each event, you must clearly indicate the information that you wish to have changed, clearly indicate that you wish to have PII about you suppressed from our database or clearly indicate the limitations you wish to put on our use of PII about you.

    We will endeavor to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. We also reserve the right, from time to time, to re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared PII about you.

  5. Retention Period. We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required by law and/or regulations.
  6. Jurisdictional Issues. The Site is hosted by ECLT from Italy, and is not intended to subject ECLT to the laws or jurisdiction of any state, country or territory other than that of Italy. ECLT does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction other than Italy. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using the Site and submitting any PII, you consent to the transfer of PII to other countries, such as Italy, which may provide a different level of data security than in your country of residence.
  7. Contacting Us. If you have any questions regarding this Policy, please contact us by email at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Please note that email communications will not necessarily be secure.
Last Updated on Wednesday, 07 April 2010 14:59