rev. August 7, 2019
Information Collection and Use
SHERPA collects three types of information on our Site and through our Services: information Users provide to enable us to communicate with them, information obtained through the normal use of our Site or Services, and Client generated and provided content. Due to the nature of our Services, it is possible that names, email addresses, videos, images, documents, voices, likenesses and/or other personal information may be contained in content uploaded by our Clients without SHERPA’s knowledge. Although SHERPA provides Terms of Service for our Site and Services, we do not control or direct our Clients’ actions and are not responsible for the content or information Clients transmit or share through our Site or using our Services. Sherpa is not responsible for any infringing, libelous, slanderous, defamatory, discriminatory, offensive, inappropriate, profane, unlawful or otherwise objectionable content or information you may encounter on our Site.
We classify the information that we collect on our Site, or through our Services, as either Personally Identifiable Information or Non-Personally Identifiable Information. Personally Identifiable Information (PII) refers to information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. Non-Personally Identifiable Information refers to information that does not by itself identify a specific individual. If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated as Personal Identifiable Information for as long as it remains combined.
We may collect Personally Identifiable Information when Clients register for the Services or when Users voluntarily provide such information on our Site. The Personally Identifiable Information we may collect through our Site, or when using our Services, may include, for example, names and e-mail addresses.
Users may choose to share Personally Identifiable Information, for example names or email addresses, by completing a form on the Site or through other voluntary submission processes. When Users provide Personally Identifiable Information, SHERPA may also provide opt-in services to receive future marketing information and communication from us, such as newsletters, email or other information. Users can choose not to receive this communication, if desired. If Users have already chosen to receive such communication, SHERPA provides the option to stop this service by clicking the opt-out link on any email communication, or by emailing a request to email@example.com.
When Users visit the Site or use our Services, we may use standard Web server log files to automatically record certain information, including destination URL, source IP address, client browser type and language, specific search requests, the date and time of the request, the results of any searches.
User information may be used to help SHERPA track the way our Site and our products are used in order to provide better services to current and potential future Clients. SHERPA may also combine User provided information with information that we collect separately, including information Users may have provided to other organizations (with consent that it can be shared) as well as public information. We do so to provide a better user experience, including customizing content for specific Users.
In general, any information Users provide may be used in the following ways:
- a) to provide the Services, including services that display customized content and advertising;
- b) to communicate with Users regarding our Site or Services, including for marketing purposes if opt-in communications have been selected;
- c) to provide information and/or Services to our Clients who provide content to us for processing, transcoding, hosting, storage and delivery, etc.
- d) to analyze, evaluate and/or improve the Site, the Services and/or market research tools.
SHERPA does not invite or knowingly permit individuals under the age of 13 to use SHERPA Services. We have no intention of collecting any information from individuals under the age of 13.
Disclosures to Third Parties
SHERPA may share your information with third parties as follows:
- With our Clients: but only if access to the Site/Services is through, or at the direction of, our Client. If Users are accessing content that has been provided to us by a Client, we may share with that Client information about such use and access. In most cases, this information will be anonymous and aggregate data.
- With our Subsidiaries, Affiliates, Agents and Representatives: for the limited purpose of providing contracted services or information to SHERPA or our Users, at our direction.
- With Service Providers: SHERPA may use other companies to perform services including, without limitation, facilitating some aspects of our Site or Service such as billing, processing credit card transactions, sending emails, and fulfilling customer service requests. These other companies may be supplied with or have access to your information solely for the purpose of providing these services to Users on our behalf.
- With Business Partners: When Users make purchases or engage in promotions offered through our Site, we may share information with the businesses with which we partner to offer products, services, and promotions. When Users elect to engage in a particular business partner’s offer or program, such engagement authorizes us to provide User related information to that business partner. These companies have agreed to treat SHERPA provided User information in the way we authorized, and to have procedures in place to protect that information with at least the same level of protections as we provide. We do not share the information you provide with third parties for their direct marketing purposes unless Users affirmatively agree to such disclosure.
- Special Circumstances: We also may disclose User information, including Personally Identifiable Information, in the following circumstances:
- In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law;
- When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Site’s terms and conditions or other agreements or policies.
- In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy. We will endeavor to contact affected Users in the event of any of these transactions, but we do not promise to do so.
If at any time you are uncertain about whether or not your personal information will be provided to a third party, please feel free to contact us at: firstname.lastname@example.org
SHERPA follows Information Security best practices and employs a full suite of physical, technical and procedural controls to protect Personally Identifiable Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and when stored on SHERPA systems or on systems of third-party vendors retained by SHERPA.
Storage and Processing of Personal Information
Personally Identifiable Information collected on the Site or through the Services may be hosted, stored, processed, or supported in the Users country of residence, or any other country in which SHERPA or its affiliates, subcontractors or agents maintain facilities. By using the Site, Users consent to the transfer of information outside of their country of residence. If information is transferred outside the country of residence, it will be treated in accordance with applicable data protection laws. Further, User’s Personally Identifiable Information may be directed to a third-party sites administered and hosted by a third-party vendor retained by SHERPA for processing, provided, that in such event, the third party vendor will have no right to use any such information except as necessary to fulfill its services to SHERPA. SHERPA will only retain User information for a reasonable period and not longer than allowed by applicable law.
How to Correct or Remove Personally Identifiable Information
If you do not want your personally identifiable information collected, please do not submit it to us. If you have already submitted this information and would like to review, correct or remove it from our records, please contact your community facilitator or email@example.com.
Safe Harbor Compliance
SHERPA has certified its participation, and compliance with, the U.S. Department of Commerce Safe Harbor framework regarding the transfer of personal information from European Union member countries and Switzerland to the United States. The principles of Safe Harbor compliance are notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.
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