Privacy Policy

Privacy Policy

Effective February 7, 2019

WELCOME!

We take your privacy seriously and know you do too. This Privacy Policy is here to help you understand how we collect, use, disclose, and process your personal data. We also describe your choices and rights with respect to how we process your personal data. Please read this policy carefully.

WHO WE ARE

This is the Privacy Policy of The Foundation for a Better Life (“FBL,” “us,” “our,” or “we”), a Colorado non-profit organization. You can contact us at info@passiton.com.

APPLICABILITY

This Privacy Policy applies to our websites that link to or post this Privacy Policy, including www.passiton.com, www.pasala.org, www.umavidamelhor.org, www.values.cn.com, www.passiton-media.com (the “Media Site”), and any subdomains or mobile versions of these sites (collectively, the “Site(s)”).

AGREEMENT

This policy is incorporated into the Terms of Use governing your use of any of our Sites. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in our Terms of Use. Supplemental policies may also apply.

Following notice to you (including posting on this Site) or your acknowledgement of this Privacy Policy (including any updates), your continued use of any of our Sites indicates your consent to the practices described in this Policy.

THIRD PARTIES

This Privacy Policy does not apply to information collected by third parties, for example, when you visit a third party website or interact with online advertisements or other third party content, unless and until we receive your information from those parties. Please review those third-parties’ privacy policies before disclosing information to them. See our list of third parties for information regarding sources and recipients of personal data.

COLLECTION AND USE OF PERSONAL DATA

PERSONAL DATA WE COLLECT

We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):

Identity Data:

Personal Data about you and your identity, such as your name, ID number, photo, username and password (if you use our Media Site), and other Personal Data you may provide on various forms or in an account profile on our Media Site.

Contact Data:

Personal Data used to contact an individual, e.g. email address(es), physical address(es), phone number(s), or social media or communications platform usernames, as well as a name or other salutation.

Device Data:

Personal Data relating to your device, browser, or application e.g. IP addresses, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.

Preferences Data:

Personal Data relating to your preferences, interests, personal demographics (e.g. country from which you are accessing our Site), your “likes,” and other information provided to us via social media services and advertising technologies, including any other categories of information (such as Identity Data or Device Data linked to such information).

Special Category Data:

As defined in the EU General Data Protection Regulation, this includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, or information relating to sex life or sexual orientation. (Note: this Personal Data may be subject to additional restrictions, and we do not intentionally collect any of this data.)

PROCESSING OF PERSONAL DATA

ACCOUNT REGISTRATION

Data:

You may be able to register and create an account on our Sites. Registration is optional in most cases (although it may be required for you to obtain content through our Media Site). If you choose to register, we will process Identity Data, Preferences Data, and Contact Data.

Uses:

We use the Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account. Subject to Your Rights and Choices, we may also use the Identity Data and Preferences Data as part of our efforts to improve our Sites and to create a personalized user experience, and we may process the Identity Data, Preferences Data, and Contact Data in connection with promotional communications, requested emails and materials, and use analytics.

CONTENT DOWNLOADS AND REQUESTS

Data:

We process Identity Data, Preferences Data, and certain Contact Data when you complete a content download or request on our Sites, including downloading any of our billboards, ecards, quotations, and videos or requesting posters and other digital media for schools.

Uses:

We use the Identity Data and Contact Data as necessary to complete and provide you with important information regarding your download or request. Subject to Your Rights and Choices, we may process Identity Data and Preferences Data to improve our services and create a personalized user experience, and in connection with promotional communications and use analytics.

PROMOTIONAL COMMUNICATIONS

Data:

We may process Identity Data, Device Data, Preferences Data, and Contact Data when you enroll to receive, and when you open or interact with, our electronic promotional communications. Note, you may be enrolled with your consent or, where allowed, in connection with account registration, or a download. We may also receive your Contact Data and send you content if someone you know requests to send you content through our Sites.

Uses:

Subject to Your Rights and Choices, we may use the Identity Data, Device Data, Preferences Data, and Contact Data to improve our services and to create a personalized user experience, and in connection with promotional communications and use analytics.

SPECIAL PROMOTIONS AND OFFERS

Data:

We may process Identity Data, Preferences Data, and certain Contact Data if you choose to register for special promotions and offers such as sweepstakes or contests. Some special promotions and offers are operated/controlled by us, and others are operated/controlled by our third party partners. We may receive this data from third parties to the extent allowed by the partner; otherwise, this Privacy Policy will not apply.

Uses:

We use this Identity Data and Contact Data as necessary to carry out special promotions and related transactions. Subject to Your Rights and Choices, we may also use this Identity Data and Preferences Data to improve our services and to create a personalized user experience, and we may process this Identity Data and Contact Data in connection with promotional communications and use analytics.

Note:

If you win a promotion, your acceptance of a prize may allow us to make certain Personal Information public, e.g. posting your name on a winner’s page. See the applicable program’s terms for details.

USER CONTENT & SOCIAL MEDIA

Data:

We process Identity Data, Preferences Data, Contact Data, and any other data in or relating to your User Content if you choose to submit User Content (e.g. comments, stories, forum and social media posts, billboard creation, etc. as defined in our Terms of Use) through our Sites. Although we do not request any Special Category Data, we recognize that you may provide this to us when you submit User Content through our Sites. If you use a social media service to post User Content that references our official accounts, your comment or content may appear on our Sites, and we may receive this and other data from a third party if provided to us by a third party (e.g. social media platform).

Uses:

We use Identity Data and Contact Data as necessary to feature User Content and for integration with social media on our Sites. Subject to Your Rights and Choices, we may also use Identity Data and Preferences Data to improve our services and to create a personalized user experience and we may process Identity Data and Contact Data in connection with promotional communications and use analytics.

Note:

Any User Content you provide may be made public as soon as you post it on our Sites. We may review User Content before it is made public but make no guarantee that we will do so in every instance. All User Content posted is your sole responsibility. Ensure that if you submit any User Content containing photos or other personal information of other parties, you have that party’s consent to do so.

COOKIES AND SIMILAR TECHNOLOGIES

Data:

We, and certain third parties, may process Identity Data, Device Data, Contact Data, Preference Data, and certain User Content when you interact with cookies and similar technologies on our Sites. We may receive this data from third parties. Please note that the privacy policies of third parties may apply to these technologies and information collected.

Uses:

Subject to Your Rights & Choices, we use this information as follows:
(i) for “essential” or “functional” purposes, such as to enable certain features of the Sites, or keeping you logged in during your session on the Media Site;
(ii) for “analytics” and “personalization” purposes, consistent with our legitimate interests in how the Sites are used or perform, how users engage with and navigate through the Sites, what sites users visit before visiting our Sites, how often they visit the Sites, and other similar information, as well as to modify the content visible to you, the language in which our Sites appear, and otherwise tailor the Sites for your use. Our Site uses Google Analytics to obtain information about our Site’s users, and we may also link our Facebook app IDs to our Sites to learn more about visitors to our Sites and to see if you like or share our content; and
(iii) (iii) for “retargeting” or similar advertising purposes, so that you can see advertisements from us on other websites. These technologies and the data they collect, may be used by advertisers to deliver ads that are more relevant to you based on content you have viewed, including content on our Sites. These tracking technologies may also help prevent you from seeing the same advertisements too many times, and help us understand whether you have interacted with or viewed ads we’ve delivered to you. This collection and ad targeting may take place on third-party websites that participate in the ad network (e.g. any advertisements delivered by that ad network on a third party website).

Note:

Some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in use analytics using this data.

SPECIFIC PROCESSING PURPOSES
PERSONALIZATION

Consistent with our legitimate business interests, we may personalize our Sites. To do so, we may link together and analyze the Personal Data that we hold about you. Personal Data processed for personalization purposes, whether or not linked, may be augmented with Preferences Data. We may create Preferences Data, or obtain it from third parties, using Personal Data we hold about you. We process Preferences Data so that our communications and Sites are more relevant to you. For example, we may provide better recommendations to you, tailor content and communications to your interests, offer content in the language you choose, and use the information to guide overall improvements to our services. We may also use Preferences Data in connection with use analytics. See Your Rights and Choices for information about how you can limit or opt out of this processing.

USE ANALYTICS

We, and certain third parties operating on or through our Sites, may engage in use analytics by tracking and analyzing your interaction with and use of the Sites. This enables us to better understand how our users interact with our Sites. This process may include various parties and service providers, and may include Preferences Data, Device Data, Identity Data, and at times, Contact Data in order to more accurately monitor and analyze use of the Sites. The parties that control the processing of Personal Data for use analytics purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have used certain services. In some cases, these parties may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to direct services to, determine whether and how services you use are effective, and may augment your profile with information derived from these observations. See Your Rights and Choices for information about how you can limit or opt out of this processing.

PROMOTIONAL COMMUNICATIONS

Consistent with our legitimate business interests, we (or if appropriate, our affiliates or trusted third parties) may send you promotional communications to the extent allowed by law: if you sign up for such communications, download curriculum from us, register on our Sites or for a promotion or contest with us or a partner, or in connection with your communications with, or submission of User Content to, us. These communications may be personalized. See Your Rights and Choices for information about how you can limit or opt out of promotional communications.

ADDITIONAL PROCESSING

If we process Personal Data in connection with our Sites in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to Your Rights and Choices) unless otherwise stated when you provide it. Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process information as necessary to fulfil our legal obligations, protect the vital interests of any individuals, or otherwise in the public interest. Please see the data sharing section for more information.

Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients:

Service Providers:

In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers who provide certain services or process data on our behalf.

Affiliates:

In order to streamline certain business operations, improve personalization, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our users, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.

Partners:

We may share your Personal Data with certain partners in connection with promotions, events, and services that are promoted, managed, supported, or otherwise undertaken with that third party.

Marketers:

In order to improve personalization, deliver more relevant information to you, and develop better products and services, we may share certain Personal Data with our affiliates and trusted third parties for promotional, advertising, or other purposes.

Social Media:

If you use any social media plugin, API, or other similar feature, use a hashtag or similar link, or otherwise interact with us or our Sites via social media, we may make your post available on our Sites or to the general public. We may share Personal Data or other information in the post to the extent permitted by the relevant social media service.

Corporate Events:

Your Personal Data may be processed if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Legal Disclosures:

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

INTERNATIONAL TRANSFERS

We operate and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU-U.S. Privacy Shield Framework, the Standard Contractual clauses, or other adequacy mechanisms, or pursuant to exemptions under EU law.

Your Rights & Choices

YOUR RIGHTS

Subject to the rights granted to other individuals, and our rights to limit or deny access/disclosure under applicable law, certain individuals have the following rights in their Personal Data. Note, we may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. You may exercise your rights by contacting us:

Access:

You may receive a list of your Personal Data we process to the extent required and permitted by law.

Rectification:

You may correct any Personal Data that we hold about you to the extent required and permitted by law. For account data, you may be able to make changes via your account settings menu on the Media Site, and you may otherwise make changes by contacting info@passiton.com.

Erasure:

To the extent required by law, you may request that we delete your Personal Data from our systems.

Data Export:

To the extent required by law, we will send you a copy of your Personal Data in a common portable format of our choice.

Direct Marketing:

Residents of California (and others as required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us.

Regulator Contact:

You have the right to contact or file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

YOUR CHOICES

It is possible for you to use some of our Sites without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process:

Consent:

If you consent to processing, you may withdraw consent any time, to the extent required by law.

Communications:

You have the choice to opt-out of processing related to promotional or other communications or to withdraw your consent if communication was initiated through consent. You may exercise your choice via the links in our communications or by contacting us re: communications.

Profiling & Personalization

You may opt out of the creation or other processing of Preferences Data by automated means, and object to processing for personalization purposes, to the extent applicable law gives you the right to do so. Note that we may not be required to cease certain types of processing based solely on an objection (for example, where we must comply with applicable legal requirements).

Cookies & Similar Technology:

If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out. Our Site does not respond to your browser’s do-not-track request.

Use Analytics:

You may opt out of or withdraw your consent to certain aspects of use analytics. You must opt out of third party services directly via the third party. For example, to opt out of Google’s use of cookies, visit Google’s Ads Settings, here. To learn more about how to opt out of DoubleClick’s use of cookies, visit the DoubleClick opt-out page, here. To opt out from Facebook Custom Audience Pixel, visit their customer support page here. To learn more about how to opt out of Twitter’s use of audience pixels, visit the Twitter help page here. If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices or the Network Advertising Initiative at www.networkadvertising.org/optout_nonppii.asp. You can limit or opt out of our processing for certain use analytics by contacting us.

Other Processing:

You may have the right under applicable law to object to our processing of your Personal Data for certain purposes. Note that we may not be required to cease processing based solely on an objection.

Security

We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.

Data Retention

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate and requested.

Minors

Our Sites are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your use of the Digital Service following notice of any changes indicates acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquiries:

Physical address:

555 17th St., Ste 960
Denver, CO 80202

List of Third Parties

We may receive and disclose personal data to/from third parties. The following is a list of third parties with whom we may share data or which may engage in processing:

Data recipients:

Google Analytics (Analytics providers)
Facebook, Twitter (Social media services)
Amazon (Content distribution and file storage)
Advanced Digital Services (Delivery of requested materials)

Note:

This list may be incomplete, and is subject to change without notice. Additional or specific parties are identified generally in the Privacy Policy, and specific parties may be identified at the time of an interaction. Please contact us re: general inquiries for more details on data recipients and sources, or if you have questions.