BLEXIT Foundation, Inc. Privacy Policy

Blexit Foundation, Inc.  Online Privacy Policy

Effective JANUARY 2021

BLEXIT Foundation Inc., a Delaware nonstock corporation (“Blexit” "we", "us" or "our" in this privacy policy) is a noncommercial is described as a public charity under section 501(c)(3) of the United States Internal Revenue Code.  Blexit respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how Blexit handles your personal information after receiving it.  This Privacy Policy governs Blexit’s use of your information on the Blexit website (https://blexitfoundation.org), and includes your use of the materials, programs, contributions, sales and other use of Blexit brand (collectively, “Website”).

Please read this Online Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

  1. Children Under the Age of 18.

Our Website is not intended for children under 18 years of age without parent consent and supervision. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18 do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent and supervision, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at set forth in paragraph 16 herein.  

     California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see California Privacy Rights Notice at https://oag.ca.gov/privacy/facts/online-privacy/child-privacy for more information.

  1. The Services.

Through its Website, Blexit provides online information, forums, videoconferencing, webinars, and other educational materials, goods for sale, opportunities to donate, and other services (collectively the “Services”).

  1. Types of Information Collected and Stored
  1. Personal Information Summary.

When you engage in activities such to use Blexit’s branded services on our website, such as create a website user profile on our website, sign up to receive a publication, register to become a member, register for educational materials, register for a conference or other event hosted by Blexit, shop on our website, or otherwise use our website, Blexit may gather your personally identifiable information (collectively “Personal Information”).  

Your Personal Information may include, but is not limited to, your name, address, phone number, images, photograph, video and/or other graphic representations, your voice data, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Blexit or its authorized agents.  

By using the Website and the Services, you agree to allow Blexit and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

  1. Specific types of data we collect about you.  For the purpose of providing the Services and our legitimate business purposes, We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Audio-Visual Data.  When you participate in Blexit programs, forums, Zoom calls, video-conferences, webinars, and other interactive media, you may choose to provide to Blexit digital audio visual information about you including images, photograph, videos and/or other graphic representations, and your voice data.  Whether you provide such Audio-Visual Data is completely up to you, and your decision to not provide such Audio-Visual Data will not adversely affect your ability to use the Service.  
  4. Financial Data.  When you use Blexit website to shop for or to purchase Blexit conferences, educational materials, make donation or contributions, register for Blexit programs, or shop or purchase merchandise, books, programs or other materials, Blexit utilizes third-party payment processors and online shopping portals as its agents (“Payment Agents”) to provide information about such transactions, process your payment and provide payment verification to Blexit concerning your payment.  Blexit and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information.  Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant.  As a result, Blexit does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary.  For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.  
  5. Technical Data includes internet protocol (IP) address, your Blexit login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  6. Profile Data includes your Blexit username and password, Blexit purchases or orders made by you, your interests, preferences, feedback and survey responses.  
  7. Usage Data includes information about how you use the Blexit website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  9. User Contributions.  The Website may contain message boards, forums, IM’s or direct messaging, images, audio files, webinars, Zoom and other videoconferencing services, chat rooms, personal web pages or profiles, forums, bulletin boards, and other interactive features (collectively, "Interactive Services") that allow You to post, submit, publish, display, or transmit to other users or other persons content, Your own image, video stream, voice data and materials on or through the Website.  These types of data are collectively named “User Contributions” herein.  
  10. Aggregated Data / Analytics Information.  We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Blexit website, Blexit gathers this Aggregated Data related to individuals’ website visits.  This information is used solely to measure and improve our website and services and to better serve our members and customers.  Blexit uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:  
  1. Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.
  2. Non-personal information, such as language, zip code, area code, location, and the time zone.
  3. Blexit website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Blexit website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.
  1. Sensitive Information.

We do not collect the following Special Categories of personal data about you.  Such Special Categories include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  Through your participation in the Services, you may, but need not, freely and voluntarily choose to post, share, provide contributions, or otherwise disclose Personal Information described within such Special Categories.  Your sharing of Special Categories of personal data will not be requisite for your participation in the Services and We cannot guarantee the privacy of such disclosures described in this Section.  

  1. Cookies and Browser “Do Not Track” Notice
  1. Blexit may use cookies on your computer.  A cookie is a small text file sent from a website and stored in a user's web browser while the user is browsing that website.  Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user's previous activity.  Blexit does not, at present, permit third party advertisers on its Website.  In the event that Blexit chooses to permit third party advertisers, such third parties will not have access to Blexit cookies, but they may use their own cookies on your computer.  Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies.  Blexit does not correlate its use of cookies with your Personal Information.  
  2. Blexit does not respond to browser Do Not Track (“DNT”) Signals.   Blexit websites may utilize page tags or web beacons to track information related to user visits as a part of Blexit data analytics processes and user experience customization as described below.  Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website.  Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website.  Such technologies enable us to improve and customize user experiences while users visit our website.  Blexit does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.  
  3. Blexit may employ third party data analytics firms to track and analyze traffic on the Blexit website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking.  These services also use cookies to accomplish such analytics-related services.  Blexit’ third party analytics firms, process the Personal Information they receive through the use of cookies in the aggregate.
  4. Third parties that may advertise on Blexit websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Blexit website.  Such information may contain a visitor’s IP address.  Third parties may not collect identifying Personal Information from the Blexit website unless you provide it to such third parties.  
  5. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
  1. Keeping Information Updated

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

  1. Security of Personal Information

Blexit takes the security of your Personal Information very seriously.  When your Personal Information is stored by Blexit, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure.  While Blexit will use all reasonable means to protect your Personal Information, Blexit cannot guarantee the security of your transmissions of such Personal Information, and you use the Blexit website at your own risk.  If you suspect your Personal Information has been compromised, please notify Blexit Customer Service using the contact information provided below.  

  1. How we Collect Your Personal Information.  We use different methods to collect data from and about you including through the following methods.  
  1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. apply for our Services;
  2. subscribe to our Services or
  3. receive our publications;
  4. request marketing to be sent to you;
  5. enter a competition, promotion or survey; or
  6. give us feedback or contact us.
  1. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  2. Technical Data from the following parties:
  1. analytics providers such as Google based outside the EU;
  2. advertising networks based inside OR outside the EU; and
  3. search information providers based inside OR outside the EU.
  1. Contact and Financial from providers of technical, payment and delivery services based inside OR outside the EU.
  2. Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
  3. Identity and Contact Data from publicly available sources.
  1. How Blexit Uses and Shares Your Information
  1. General Information and Your Rights.  Blexit limits its use of your Personal Information to the stated purposes for which such information is collected.  In some cases, Blexit may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  You have the right to the following regarding your Personal Information transferred to Blexit:  
  1. To know the types of Personal Information Blexit collects;
  2. To know the purposes for which it collects and uses your Personal Information;
  3. To know type or identity of third parties to which Blexit discloses your Personal Information, and the purposes for which it does so;
  4. To access and update your Personal Information; and
  5. To know the choices and means Blexit offers you for limiting the use and disclosure of your Personal Information.
  1. Other Blexit Services.

Blexit may use your Personal Information to provide services to you upon your request.  Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Blexit website, emailing you updates concerning Blexit products and services, and personalizing your visits to Blexit website.  

You may opt-out of the use of your Personal Information as described in this Section by contacting Blexit Customer Service using the contact information provided below.

  1. Blexit Internal Data Sharing 

Blexit may also share your Personal Information with other Blexit offices or Blexit affiliates       in the country in which you reside and in other countries.

  1. Information Sharing with Third Parties
  1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
  2. Blexit may utilize third-party service providers and data processors that process your Personal Information solely on Blexit’ behalf (“Agents”).  When Blexit transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes.  Blexit will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the Principles.  Blexit remains responsible and liable if the Agents that Blexit engages to process your Personal Information on Blexit’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Blexit proves that it is not responsible for the event giving rise to the damage.
  3. Blexit uses consultants and third party vendors, and may share your Personal Information with such consultants and vendors, if necessary, for delivery or administration of the Blexit Services.  All parties with which Blexit shares your personal information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.  Blexit’ agreements with third parties provide that third parties will delete your personal information upon request.  
  4. Blexit may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.
  5. Blexit uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services.  All parties with which Blexit shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.
  6. Blexit may partner with third parties to provide other specific services, including, but not limited to registration for Blexit conventions, meetings, physical gatherings and events, and other Blexit educational materials and Services.  When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services.  Blexit may auto-populate forms utilized by these third parties with data contained in Blexit managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services.  All parties with which Blexit shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.
  7. Blexit may share your Personal Information with third parties whose programs and services align with Blexit’s charitable and educational mission.  These third parties may send you emails, text messages, promotional materials, and solicitations for goods and services.  Blexit may request your consent prior to sharing your Personal Information with third parties described in this section.
  1. Other Possible Disclosures.

In addition to the other disclosures stated herein, Blexit may share your information in the following ways:

  1. To comply with applicable laws, regulations, legal processes, or government enforced orders,
  2. To enforce applicable terms of service, protect our legal rights or defend against legal claims,
  3. To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,
  4. To comply with Blexit’ obligations to address complaints arising under its obligations, including disclosure to EU Data Protection Authorities, or other necessary entities.
  5. To guard against harm (whether actual or potential) to the legal rights, property or safety of Blexit, our visitors or the general public as required or permitted by law.
  1. International Transfers
  1. We share your personal data within Blexit. This will involve transferring your data outside the European Economic Area (EEA).
  2. Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
  1. Blexit Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer, student or member.

(a) Identity

(b) Contact

(c) Financial

Performance of a contract with you

To register you for Blexit events, conferences and programs.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e)  Financial

a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To process and deliver your orders for Blexit goods and services  including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To conduct conferences, keeping record of attendees, webinars, forums, educational programs and otherwise provide the Services.  

(a) Identity

(b) Contact

(c) Profile

(d) Audio-Visual

(e) User Contributions

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable your full participation, and to enable full functionality of the website, provide educational content, and to enable full functionality of the Services).

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c)  Managing Blexit member services.

(d)   Administering, maintaining monitoring, and managing Blexit degrees, certifications, and related  examinations and programs.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e)  Financial

(f)  Transactional

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) User Contributions

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and improve our services to our users)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) User Contributions

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and to inform our marketing strategy)

To develop new marketing materials and advertising.  

(a) Audio-Visual

(b) User Contributions

Necessary for our legitimate interests (to grow and develop and grow our educational services).

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(c) Audio-Visual

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To introduce you to third parties who may provide goods or services that may be of interest to you.  

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to grow and develop our base of business networks and collaborative relationships.)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products and educational services)

  1. Data retention
  1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  1. Blexit Email Uses
  1. Blexit never rents or sells email addresses to outside parties without your consent.  Occasionally, you may wish to receive information or communication from a Blexit participant.  In that instance, you will be asked for permission to share your email address.
  2. After you make a donation, purchase goods through our online store, enroll in COLLC programs or sign up for newsletters or other communications, you will receive information about Blexit products, services, and educational offerings that relate to your areas of interest unless you choose to opt-out.  If you have questions or concerns about Blexit's Online Privacy Policy or wish to no longer receive such offers (opt-out), please contact Blexit Customer Service using the contact information provided below.  
  1. How to Access or Change Your Personal Information
  1. To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may contact Blexit Customer Service using the contact information provided below.  
  2. In your request, clearly state what information you would like to have changed or updated.  Blexit will try to comply with your request as soon possible.
  3. The deletion of Personal Information and other changes to the data retained by Blexit as described above may result in the deletion or limitation of the Services Blexit provides, including, but not limited to, maintaining and making accessible Blexit classes, courses, videoconferences, and other Services. Blexit may retain certain Personal Information to pursue legitimate business interests, fulfill contract obligations, conduct audits, comply with (and demonstrate compliance with) other legal obligations, resolve disputes, and enforce agreements.
  1. Your Legal Rights.  You have the right to:
  1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  1. If you want us to establish the data's accuracy.
  2. Where our use of the data is unlawful but you do not want us to erase it.
  3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  1. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  2. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  1. Notices of Changes to Privacy Policy

In the event of any change to the Blexit Online Privacy Policy, notice of such changes will be posted on the Blexit website.  Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Blexit website. Your use of the Blexit website following these changes means that you accept the revised Online Privacy Policy.

  1. Contact Blexit

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Blexit Customer Service
[email protected]

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