Effective Date: May 20, 2018
- 1. The Information We Collect and Use
A. Non-Personally Identifiable Information. When you visit a Website, we may collect certain data that does not tell us specifically who you are. This is “Non-Personally Identifiable Information.” It includes things like your Internet Protocol (IP) address, browser type, and the last domain you visited before coming to our Website or the domain you go to when you leave. It also includes various statistical data such as which pages you visit on our Websites, how long you stay on them, and what you click.
We also may use a small piece of code (sometimes referred to as “1×1 clear pixel,” “Web beacon” or “clear GIF”) placed in the pages of the Websites to help us gather additional information about which parts of the site receive the most visitors and other user traffic patterns, and enable us to administer the site.
No Personally Identifiable Information (see below) is collected through our cookies or Web beacons however we may, from time to time, allow third-party companies to serve ads and/or collect certain anonymous information when you visit our website. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. The companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt out of this type of advertising, you can visit http://www.networkadvertising.org/managing/opt_out.asp.
We may use Personally Identifiable Information to fulfill your requests, respond to your inquiries and provide other services, and to alert you to information, offers, or publications in which we think you may be interested. The emails that we send contain links that enable you to “unsubscribe” from such mailings.
We do not sell Personally Identifiable Information or other information you make available to the Websites, or share such information with third parties, except as described below.
From time to time, we may partner with unaffiliated companies or individuals for market research, product development or similar purposes. These companies or individuals may be provided with access to Personally Identifiable Information and Non-Personally Identifiable Information, but we will require by contract that they agree to maintain the confidentiality, security and integrity of such information. We also may subcontract with other companies and individuals to do work on our behalf; they may be provided with access to Personally Identifiable and Non-Personally Identifiable Information, but only as needed to perform their functions.
We do not disclose your Personally Identifiable Information to third parties in connection with a corporate transaction where all or a portion of our business (e.g., a portion that includes our customer lists) is sold or transferred. We also may disclose your Personally Identifiable Information if disclosure is required by law or as part of a lawsuit or government investigation or proceeding, or in order to permit us to exercise or preserve our legal rights or take action regarding potentially illegal activities or to protect the safety of any person.
- 2. Data Security
Freethinkernation.com cannot ensure or warrant the security or privacy of any information you transmit to us. We attempt to follow policies and procedures that will protect against unauthorized access to your Personally Identifiable Information. But we can make no guarantees or promises in this regard, and you provide information to us at your own risk.
- 3. Children
This site is not directed at children under the age of 17 and we endeavor not to knowingly collect any Personally Identifiable Information from children under the age of 17. If a parent or guardian believes that this site has collected the Personally Identifiable Information of a child under the age of 17, please contact firstname.lastname@example.org.
- 4. Access to your information
- 5. How To Contact Us
You may contact Freethinkernation.com regarding our privacy practices at the following address:
We have been preparing for the recent European Union General Data Protection Regulation (GDPR). The GDPR means there are new and updated requirements as to how we process personal data and as such, we have adapted to these changes, implemented them and intend to fully reflect the new legislation. The GDPR legislation including official translations can be downloaded from this website. We have always been committed to strict data privacy and security, and will continue to do so with changing laws.
At freethinkernation.com we take privacy seriously:
- We aim to be fair, open and honest about who we are and what we are going to do with the personal data we collect.
- We aim for the information we provide to you about the processing of your personal data to be concise, transparent, easy to understand and easily accessible.
Our privacy obligations
freethinkernation.com is a Canadian website.
We will review this policy regularly, and we may update it from time to time.
The types of personal information we collect and hold
We collect personal information about our users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect.
How we collect personal information
Information that you specifically give us
While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.
We may request, collect, or process the following information:
- Account Details – username, password, profile picture.
- Contact Details – email address, phone number.
- Location Details – physical address, billing address, timezone.
- Identity Details – full name, proof of identity (e.g. drivers licence, passport), proof of address (e.g. utility bill), photograph of the user.
- Financial Information – credit card details, wire transfer details, payment processor details (e.g. skrill, paypal), tax numbers.
- User Generated Content – project descriptions and attachments, bid description, user profiles, user reviews, contest descriptions and attachment, user messages etc.
Information that we collect from others
Users have the ability to invite non-users to our platform by providing contact details such as email address. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of the invite systems.
Your payment provider may transmit information about the payment that we may collect or process.
In some situations, personal information of users may be collected from public sources.
We may collect or process the following information:
- Basic Details – username, profile picture.
- Contact Details – email address, phone number.
- Location Details – Physical Address, billing address, timezone.
- Financial Information – payment account details (e.g. paypal email address and physical address), and wire transfer details.
- List of contacts – email provider address book.
- User Generated Content – user profile.
Information we collect as you use our service
We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.
In order to deliver certain products or services, we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data.
When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.
We may collect or process the following information:
- Metadata – IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
- Device Information – device identifier, device type, device plugins, hardware capabilities, etc.
- Location – GPS position.
- Actions – pages viewed, buttons clicked, time spent viewing, search keywords, etc.
Links to other sites
How we use personal information
The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:
- to provide the service or product you have requested;
- to facilitate the creation of a User Contract (see Terms of Service for more information);
- to provide technical or other support to you;
- to answer inquiries about our services, or to respond to a complaint;
- to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
- to allow for debugging, testing and otherwise operate our platforms;
- to conduct data analysis, research and otherwise build and improve our platforms;
- to comply with legal and regulatory obligations;
- if otherwise permitted or required by law; or
- for other purposes with your consent, unless you withdraw your consent for these purposes.
The ‘lawful processing’ grounds on which we will use personal information about our users are (but are not limited to):
- when a user has given consent;
- when necessary for the performance of a contract to which the user is the party;
- processing is necessary for compliance with our legal obligations;
- processing is necessary in order to protect the vital interests of our users or of another natural person.
- processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.
We use automated decision when helping matching users to jobs. The primary way this occurs is through how we rank users. These rankings are produced by analyzing user-generated content, user activity and the outcome of jobs; in this context, user-generated content will include reviews that users receive when completing jobs. More information on these ranking guides can be found in our community articles. Automated decision making is also used to recommend potential jobs to our users and as a part of our marketplace security systems.
When we disclose personal information
Our third party service providers
The personal information of users may be held or processed on our behalf outside Canada, including ‘in the cloud’, by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party service providers include:
- Cloud hosting, storage, networking and related providers
- Payment and banking providers
- Marketing and analytics providers
- Security providers
Third party applications
Other disclosures and transfers
We may also disclose your personal information to third parties for the following purposes:
- if necessary to provide the service or product you have requested;
- we receive court orders, subpoenas or other requests for information by law enforcement;
- if otherwise permitted or required by law; or
- for other purposes with your consent.
Accessing, correcting, or downloading your personal information
You have the right to request access to the personal information freethinkernation.com holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer at email@example.com.
You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support at firstname.lastname@example.org.
Exercising your other rights
You have a number of other rights in relation to the personal data freethinkernation.com holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace – these data uses are protected against the below rights.
You have the right to:
- seek human review of automated decision-making or profiling
- opt-out of direct marketing, and profiling for marketing
- temporary restriction of processing.
Human review of automated decision making / profiling – In the case of our ranking algorithms, it is not possible to exercise this right as this ranking is a fundamental part of the marketplace that users participate in, opting out would mean not being able to participate in the marketplace. Decisions affecting marketplace security are already reviewed by humans.
Direct marketing and profiling – users can control what emails they receive through their settings page.
Erasure – Most personal information and user generated content cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protecting other legitimate users of the marketplace. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymized from the personal data.
Temporary restriction to processing – under certain circumstances you may exercise this right, in particular, if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer.
Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer.
To contact our Privacy Officer
If you have an inquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact email@example.com or firstname.lastname@example.org
I. Summary of our processing activities
We publish scholarly papers, essays, e-books, news and data. Some of this material is freely available, some of it is only available to subscribers. The following summary offers a quick overview of the data processing activities that are undertaken on our website. You will find more detailed information under the indicated sections below.
- When you visit our website for informational reasons without setting up an account, only limited personal data will be processed to provide you with the website itself (see III).
- If you are identified as belonging to a customer organisation then we collect information in order to be able to provide usage reporting to that customer.
- In case you register for one our services or subscribe to our newsletters or other promotional materials, further personal data will be processed in the scope of such services (see IV and V).
- Furthermore, your personal data will be used to provide you with relevant advertising for our services and products (see VII) and for statistical analysis that helps us to improve our website (see VIII). Additionally, we improve your website experience with third party content (see IX).
- Your personal data may be disclosed to third parties (see X) that might be located outside your country of residence; potentially, different data protection standards may apply (see XI).
- We have implemented appropriate safeguards to secure your personal data (see XII) and retain your personal data only as long as necessary (see XIII).
- Under the legislation applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see XIV).
- Personal data: means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
- Processing: means any operation which is performed on personal data, such as collection, recording, organisation, structuring, storage, adaptation or any kind of disclosure or other use.
III. Informational use of the website
When you visit our website for informational reasons, i.e. without registering for any of our provided services listed under IV and without providing us with personal data in any other form, we may automatically collect additional information about you which will contain personal data only in limited cases and which is automatically recognised by our server, such as:
Examples might include:
– your IP address;
– your device type, name and IDs;
– the date and time of your requests;
– the content of your requests;
– information on your browser version;
– your screen resolution;
– information on your operating system, including language settings.
We use such information only to assist us in providing an effective service (e.g. to adapt our website to the needs of your device or to allow you to log in to our website), and to collect broad demographic information for anonymised, aggregated use.
If you are identified by IP or equivalent method as belonging to a customer organisation such as university or a company then we will also collect the identity of that organisation and use it to create usage reports which show the organisation how much of the content we publish is being read by their students, members or employees. This information does not contain anything related to a personal login unless (a) you are a nominated administrator for that organisation or (b) your organisation specifically requires it as a part of a usage-based access contract.
The personal data automatically collected is necessary for us to provide the website, Article 6 sec. 1 sent. 1 lit. b GDPR, and for our legitimate interest to guarantee the website’s stability and security, Article 6 sec. 1 sent. 1 lit. f GDPR.
IV. Registration for our services
Access to subscription content is provided via a variety of mechanisms such as IP site licenses, login via third party federated identity providers or by an personal account with us. If your access to our content is provided by an organisation or an institution like a university or a company then they choose the access method on your behalf. A personal account is required to purchase content directly from us, or to receive personal services like newsletters and alerts.
If you need to create a personal login with us then we will store and process the following:
– Information (such as your name, user name and email address) that is provided by registration;
– Information in connection with an account sign-in facility (e.g. log-in and password details);
– Communications sent by you (e.g. via e-mail or website communication forms).
The information that is necessary for the performance of the service is labelled accordingly. All further information is provided voluntarily.
We will process the personal data you provide to:
Examples might include:
– Identify you at sign-in;
– Provide you with the services and information offered through the website or which you request;
– Administer your account;
– Communicate with you;
– (behavioural) Advertising and profiling;
– Facilitate attendance of a conference;
– Manage manuscript submissions;
– Provide access (where appropriate) to other Springer Nature group content if you so request
For this, the legal basis is Article 6 sec. 1 sent. 1 lit. b GDPR. The use of your personal data for behavioural advertising and profiling is done for the legitimate interest to improve your experience while using the website, Article 6 sec. 1 sent. 1 lit. f GDPR.
We use the personal data and contact data you provide by registration to inform you directly about our additional products and services. The use of your personal data for directly advertising related products and services is a legitimate interest for us as a provider of this website, Article 6 sec. 1 sent. 1 lit. f GDPR.
You can object to the use of your personal data for direct marketing at any time. We will then refrain from any processing to the extent it is related to such purposes. You may opt-out of direct marketing via opt-out links in any marketing communication or via user profile pages on the website (where available). You can also inform us about your objection by contacting email@example.com.
We offer notification services such as table-of-contents or new book alerts. This service is provided by means of a double-opt-in. Thus, you will receive an email containing a link by which you can confirm that you are the owner of the email address and wish to be notified via our email service. You can end this service by opting out via the link provided in each notification email. This notification service is based on your consent, Article 6 sec. 1 sent. 1 lit. a GDPR.
Registration data is kept until such time as an account deletion request is made. If such a request is received we will erase your data within 30 days. Statutory storage obligations or the need for legal actions that may arise from misconduct within the services or payment problems can lead to a longer retention of your personal data. In this case, we will inform you accordingly.
V. Information about the specific uses that require registration
You can publicly comment on our blog where we post a variety of articles to inform you about our activities. When posting a comment your name or user name will be made public. To be able to comment on our blog you will have to register as described in IV.
In addition to the extent of processing described under IV, when you post a comment we will retain some of your personal data such as your IP address and name and other metadata such as time of posting. This is necessary to defend ourselves from possible liability claims that may arise from unlawful comments posted by you and reflects our legitimate interest with regard to the legal justification of this processing activity in Article 6 sec. 1 sent. 1 lit. f GDPR.
We reserve the right to delete comments that are off-topic, spam, abusive, use excessive foul language, include ad hominem attacks or offend against legal regulations.
2. Web shop
For the use of our web shop you have to set up an account as described under IV. Your customer account retains your personal data for future purchases. You can delete the personal data as well as the account in your account’s settings. This processing is based on Article 6 sec. 1 sent. 1 lit. b.
By statutory law we are required to retain the provided financial data in relation to transactions (including address, payment and order information) for ten years. However, after 2 years we will restrict the processing of your personal data to comply with the statutory requirements and will not process the personal data any further. Regarding this, the retention of your personal data is based on Article 6 sec. 1 sent. 1 lit. c GDPR.
With your email address you can subscribe to our newsletters that provide you with the latest news about our products and services if you consent to receiving such newsletters. The legal basis for this processing is Article 6 sec. 1 sent. 1 lit. a GDPR. Your email address will be retained as long as you subscribe to our newsletters.
This service is provided by means of a double-opt-in. Thus, you will receive an email containing a link by which you can confirm that you are the owner of the email address and wish to be notified via our email service. When your subscription is not confirmed within 96 hours after the confirmation mail has been requested, the personal data you provided will not be processed for any purpose and it will be automatically erased.
You can unsubscribe from this service by opting out via the link provided in each newsletter.
VI. Automated decision making
We do not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you, however we do use your personal data to offer you content and services which we believe may be of interest.
VII. Online advertising
We present online advertising provided using the services of Google DFP, Google AdExchange, Google AdSense, Sovrn OnScroll. Respective advertisement is labelled as ”ADVERTISEMENT” or “AdChoices”. In order to do so, we collect statistical information about you that will be processed by Salesforce DMP, Oracle MOAT, Google Analytics, Google DFP, Google AdExchange, Google AdSense, Sovrn OnScroll. This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to promote our products and services. The above providers will be automatically informed about your visit on our website. For such purpose, a web beacon is used to place a cookie on your computer.
Please note that we neither have the control of the extent of personal data that is collected by the respective plug-in provider nor do we know the processing’s purpose or the period your personal data will be retained. Your personal data will be transferred to and processed inside and outside of the EEA. For further information about the potential risks of a cross border data transfer refer to XI.
It is possible that the above providers may disclose your personal data to its business partners, third parties or authorities.
You can prevent the installation of such a cookie (i) by a respective setting of your browser that blocks the installation of third party cookies, (ii) by deactivating the interest-related advertising under https://www.google.ca/ads/preferences, (iii) generally blocking cookies under https://www.google.ca/settings/ads/plugin or (iv) by deselecting the option for tracking cookies via the Springer Nature cookie preference centre.
Google AdExchange – https://policies.google.com/privacy?hl=en
Google AdSense – https://policies.google.com/privacy?hl=en
Sovrn OnScroll – https://www.sovrn.com/privacy-policy-eu/
Salesforce DMP – https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-privacy/
Oracle MOAT – https://moat.com/privacy
Google Analytics – https://policies.google.com/privacy?hl=en
Google DFP – https://policies.google.com/privacy?hl=en
For statistical analyses we use web analytics services such as Google Analytics, Webtrekk, and Webtrends to collect information about the use of this site.
General tracking information
The tools collect information such as:
– Device and browser information (operating system information, Mobile device identifier, mobile operating system, etc.)
– IP address
– Page accessed, URL click stream (the chronological order of our internet sites you visited)
– Geographic location
– Time of visit
– Referring site, application, or service
We use the information we get from the providers only to determine the most useful information you are looking for, and to improve and optimise this website. We do not combine the information collected through the use of the tools with personal data.
Depending on the provider the information generated about your use of the website may be transferred to and processed in third countries, e.g. the United States. For further information about the potential risks of a cross border data transfer please refer to section XI. The tools collect only the IP address assigned to you on the date you visit this site, rather than your name or any other identifying information. The provider will use this information in order to evaluate your use of the website, to compile reports on website activities and to provide other services relating to website and internet use to us.
The legal basis for this processing is Art. 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to analyse our website’s traffic to improve the user’s experience and to optimise the website in general.
Google Analytics / Google Tag Manager
We use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). On our behalf Google will use the information generated by a cookie for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet activity in connection with the use of the website.
IX. Third party content and social media plug-ins
1. Links to third party websites
X. Information sharing
Where personal data is disclosed to the following third parties for the purposes mentioned above the legal basis for the transfer of your personal data is Article 6 sec. 1 sent. 1 lit. b and f GDPR. Some of the recipients may reside outside the EEA. For further information about cross border transfer in general and transfers outside of the EEA see XI.
We may disclose anonymous aggregate statistics about users of the website in order to describe our services to prospective partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics will include no personal data.
We may disclose your personal data to contractors who assist us in providing the services we offer through the website. Such a transfer will be based on data processing agreements. Therefore, our contractors will only use your personal data to the extent necessary to perform their functions and will be contractually bound to process your personal data only on our behalf and in compliance with our requests.
In the event that we undergo re-organisation or are sold to a third party, any personal data we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.
We may disclose your personal data if legally entitled or required to do so (for example if required by law or by a court order).
XI. Cross border data transfers
Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.
In the case of a transfer outside of the EEA, this transfer is safeguarded by privacy the Privacy Shield and EU Model Clauses. You can find further information about the aforementioned safeguards by following this link https://ec.europa.eu/info/law/law-topic/data-protection_en
We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via our website whilst it is in transit over the internet and any such submission is at your own risk.
XIII. Data retention
We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.
XIV. Your rights
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
1. require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
2. request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
3. refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
4. object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;
5. take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators;
6. require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or
7. not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance.
You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below.
XV. Contacting us
The information you provide when contacting us at firstname.lastname@example.org will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.
XVI. Amendments to this policy