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Sample Privacy Policies

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  • Sample Privacy Policies

    Last week, the post Addressing Internet Privacy covered a number of action items that sims should take in order to come into compliance with international privacy laws. Besides software/server security and good practices around data management/usage, privacy policies are critical to compliance. In order to support our players with this, Bravo Fleet has prepared an example of the sort of policies we recommend our sims implement on their sites.

    Before we get started, a disclosure that pertains to this entire post and all other communications with Bravo Fleet, or any of its agents or representatives, on the topic of privacy:
    The information contained within this post and the communications with Bravo Fleet on this topic ("Communication") were prepared for informational purposes only. The Communication is not intended to be and should not be considered legal advice. The Communication is provided only as general information and may be incomplete and/or not reflect the most current legal developments. None of the Communication is intended to constitute an attorney-client relationship. You should not act upon any of this Communication without consulting professional legal counsel.
    Additionally, please note that these policies:
    • were designed for sims using Nova, although they may also work with mild adaptations for forum and blog software (specifically, modifying "Required Member Information", "Optional Member Information" and the uses description);
    • do not support the use of Google Analytics or other user tracking tools;
    • do not allow you to share personal information with third parties besides Bravo Fleet;
    • do not allow you to place advertisements on your site unless you are sure they do not track users;
    • do not allow you to post third-party embeds on your site that may track users;
    • do not allow you to contact users for anything not related to your sim;
    • were designed directly with consideration in mind for the laws of the United States, the state of California, the European Union, Canada, Mexico, Australia and New Zealand; and
    • do not satisfy the requirements of Russia, Kazakhstan, China, Indonesia, Columbia, and possibly other jurisdictions not directly considered.
    And finally, if you wish to use or modify these sample policies, here are the terms by which you may do so:
    Copyright 2018 Bravo Fleet. This work is licensed under the Creative Commons Attribution-NonCommercial 4.0 International license (human-readable summary: here).
    With that out of the way, the following are samples of policies (substituting out the [INSERT: SOMETHING] placeholders) that would be listed in the footer and also require agreement as part of the join disclaimer before a user signs up for the sim...

    Privacy Policy

    The [INSERT: SIM NAME] ("Service" or "We") collects and uses personal information solely for the purpose of providing an online collaborative writing environment. Where feasible, We collect personal information only with the knowledge and consent of the individual concerned ("Individual"), and, if the Individual notifies us that they wish to revoke their consent, We will make a best effort to remove all personal information related to the Individual from our Service.

    This Privacy Policy, along with our Cookie Policy, Do Not Track Policy, and Your California Privacy Rights page, define in full how the Service collects, manages and processes an Individual's personal information.

    What information is collected?

    "Required Member Information": When an Individual signs up for the Service (becoming a "Member"), We collect the Member's name, age, email address, language and timezone.

    "Optional Member Information": We allow a Member, at their discretion, to provide additional contact information, a geographic location, interests and a biography.

    "Access Logs": When an Individual visits the Service, We collect incidental personal information in the Service's logs including the Individual's IP address and user agent.

    How is information collected?

    Required Member Information and Optional Member Information are collected with an Individual's consent when the Individual signs up for the Service or edits their account within the Service. In order to participate in the Service, a Member must provide all Required Member Information. A Member may provide a pseudonym instead of their real name, if they do not wish to disclose their real name.

    Access Logs are collected by our web server and web application when an Individual uses the Service.

    Why is information collected?

    Required Member Information is collected in order to allow a Member to participate in the Service. A Member's name, email address and timezone are listed on their profile. A Member's email address will also be used to contact the Member and to send the Member story posts and other content directly related to the Service. A Member's age is only used to confirm the Member meets the legal requirements to participate in this Service.

    Optional Member Information is collected in order to allow a Member to share more details about themselves to other Members of the service.

    Access Logs are collected for diagnosing technical problems with our Service. In rare situations, We may also use Access Logs to ban an Individual found to be acting inappropriately with the Service, including, but not limited to, violating the rules of the Service, placing an undue burden on the Service or violating applicable laws ("Inappropriate Use").

    With whom is information shared?

    A Member's name, email address, timezone and Optional Member Information are shared with other Members of the Service through the Member's user profile.

    A Member's name, age, email address, timezone and Optional Member Information may also be shared with Bravo Fleet, the organization within which the Service belongs.

    Access Logs are generally not shared, although they may in rare circumstances be shared with Bravo Fleet or the [INSERT: WEBSITE HOSTING COMPANY] ("Host") to diagnose technical problems or when an Individual is reasonably believed to have committed Inappropriate Use of the Service.

    The Service or the Host may share personal information with relevant law enforcement authorities as required to comply with applicable laws. The Service will notify the Individual, if permitted by applicable laws, when this occurs.

    The Service will not share any personal information with any other parties without the Individual's consent.

    How is information protected?

    We protect all personal information using reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We are committed to managing the Service in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

    Upon request from an Individual, we will make readily available information about our practices and policies relating to the management of personal data.

    How long is information retained?

    Required Member Information and Optional Member Information is retained as long as the Individual remains a Member of the Service.

    Access Logs are retained for [INSERT: TIME BEFORE ACCESS LOGS ARE DELETED].

    How can information be removed?

    An Member may submit a request to [INSERT: ADMIN EMAIL ADDRESS] to have their account deleted and all Required Member Information and Optional Member Information removed from the Service. This will cause them to no longer be a Member.

    The Service cannot ensure that other Members do not personally retain Required Member Information or Optional Member Information shared to these other Members through the Service as described in this Policy.

    The Service routinely deletes all Access Logs, so an Individual does not need to request its removal explicitly.
    Cookie Policy

    The [INSERT: SIM NAME] ("Service" or "We") uses cookies solely for the purpose of providing an online collaborative writing environment.

    Cookies are small pieces of text sent back and forth between your web browser and a website you visit. A cookie file is stored in your web browser and allows the Service to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.

    When an Individual accesses or uses the Service, the Service may place a number of cookies in the Individual's web browser. We use both session and persistent cookies. Specifically, We use cookies to authenticate Individuals and prevent fraudulent use of accounts, and We use cookies to remember an Individual's email address when prompting the Individual to log in again.
    Do Not Track Policy

    The [INSERT: SIM NAME] ("Service" or "We") does not track Individuals over time to provide targeted advertising and therefore does not respond to Do Not Track ("DNT") signals.
    Your California Privacy Rights

    If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by [INSERT: SIM NAME] to third parties for the third parties’ direct marketing purposes. To make such a request, please email [INSERT: ADMIN EMAIL ADDRESS].
    Last edited by JonM; 05-15-2018, 03:14 AM.

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