Two Hat Security Ltd. DBA Community Sift

COMMUNITY SIFT SERVICES PRIVACY POLICY

Updated: July 22nd, 2016


Click here for our WEBSITE Privacy Policy

Two Hat Security Ltd. dba Community Sift and its affiliates (“ Community Sift ”), takes its customer’s (“ Customer ”) privacy and the privacy of its Customer’s end users (“ End Users ”) seriously.  The services provided by Community Sift to its Customers is a highly sophisticated classification tool for online communities (the “ Services ”) which has been developed (and which will continue to be modified) to foster healthy online communities, encourage, reward and increase positive engagement and allow freedom of speech with moral responsibility.

This privacy policy (“ Privacy Policy ”) governs how our Customer’s information and information regarding our Customer’s End Users is collected, used, maintained and disclosed by Community Sift using the Services that Community Sift provides to its Customers.  This Privacy Policy does not apply to websites, applications or services that display or link to different privacy statements.  For these privacy policies, please see our website privacy policy.

For our policy regarding children users, please click here.

COLLECTION OF INFORMATION

Community Sift may receive personally identifiable and non-personal identifiable information from End Users in a number of ways including, but not limited to, when our Customers use the Services to classify their online communications based on a variety of contexts (the “ User Data ”).  Our Customers may also add additional information to the User Data prior to sending the User Data to be analyzed and classified by our Services.   

The Services do not require the Customers to provide any personal identifiable information of any End User with the exception of the username (no password) generated by an End User.  The User Data may contain personal identifiable information included in online communications as well as personal identifiable information the End User has added for others to see, which, when processed through the Service, will become either redacted, stored or blocked, depending on how the policy guide (the “ Policy Guide ”) contained in the Services is configured by the Customer.

Community Sift will not: (a) modify User Data except to the extent dictated by the Policy Guides and the Services, (b) disclose User Data except as compelled by law or as expressly permitted in writing by Customer, or (c) access User Data except to enable the use of the Services or to prevent or address service or technical problems, or at Customer’s request in connection with support matters. 

Community Sift may use and reproduce aggregate anonymized User Data (as aggregated with data of other Community Sift customers) (“ Trend Data ”), provided that such Trend Data: (i) does not contain any personally identifying information as defined by COPPA law; and (ii) does not identify a User in any way. 

DATA RETENTION AND STORAGE POLICY

Our default data retention policy for User Data is 5 years. We will also purge User Data if we receive a request from a Customer or the Services are terminated by a Customer.  If a User wishes to have their User Data deleted from our servers, they must make their request through the Customer and the Customer will make this request to us.   

Community Sift uses data storage centers located throughout the world and User Data is often stored at a location or in the manner prescribed by the Customer.  The Customer may access and use the Services electronically from any location throughout the world provided that it is the responsibility of the Customer to ensure compliance with the laws of any jurisdiction from which it elects to access and use the Services. 

The Customer is responsible to implement and maintain all necessary internal security and privacy protocols and policies relating to access and use of the Services, including protocols and policies relating to permitted access to and use of the Services, protection of login credentials, and collection, use and disclosure of User Data.

HOW WE USE COLLECTED INFORMATION

The User Data is collected by Community Sift as part of the Services for the following reasons:

  • To allow the User Data to be sifted and classified as part of the Services
  • To allow us to further enhance and modify the Services in order to provide better quality filtering, classification and labeling
  • Assist us to respond to Customer service enquiries and support needs more efficiently

We may also collect anonymized information from the User Data to utilize the aggregated learnings from the Customer’s online community to improve the Services.  This includes training the artificial intelligence contained in the Services to create new rules to enhance the Services.

Except as described in this Privacy Policy, Community Sift does not rent, sell, or share personally identifiable information collected by Community Sift with other third parties unless we have the Customer’s consent, or under the following circumstances noted below.

  • With third party vendors, consultants and other service providers who work for us and need access to your information to do that work;
  • To comply with laws or to respond to lawful requests and legal process;
  • To protect the rights and property of Community Sift, our agents, customers, End Users, and others including to enforce our agreements, policies and Terms of Service;
  • In an emergency to protect the personal safety of Community Sift, its customers, or any person;
  • We may also share aggregated or anonymized information in a form that does not directly identify you or your End Users with third parties.

Any third party vendors, consultants or other service providers are held to the same standards as Community Sift.


OUR POLICY REGARDING CHILDREN

We have designed the Services to assist our Customers in their compliance with the Children’s Online Privacy Protection Act (“ COPPA ”) and other relevant legislation respecting the collection and use of information from children.  To learn more about COPPA, you may reference this simple one-page informational guide from the kidSAFE Seal Program.

This compliance is achieved mainly by ensuring a more restrictive policy guide is in place when the Services classifies and filters online communications from sites or services which have End Users ages 13 and younger. This more restrictive policy guide is designed to either redact or block all or virtually all personal information which has been flagged by the Customer for classification and filtering.

Community Sift does not knowingly store or solicit any “personal information” (as that term is defined under COPPA) from anyone under the age of 13 on the Community Sift website or through the application of the Services.  If you are under the age of 13, please do not attempt to send any personal information about yourself to us, including your name, address, telephone number, or e-mail address.  If you are a Customer, you must abide by the Terms of Service regarding use of the System, and ensure COPPA (or similar legislative) compliance by enabling the policy guide appropriate for your child-directed site or service.  If you are an End User and you believe that we might have any personal information from or about a child under the age of 13, please contact the Customer responsible for that online community. They will validate this request and contact us directly.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Community Sift will use reasonable commercial efforts to maintain administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Customer Data in its possession or under its control. 

Community Sift endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal identifiable information in question. These safeguards are designed to prevent your personal identifiable information in the possession or under the control of Community Sift from loss and unauthorized access, copying, use, modification or disclosure.

QUESTIONS AND COMPLAINTS: THE ROLE OF THE PRIVACY OFFICER

The Privacy Officer is responsible for ensuring Community Sift’s compliance with this Privacy Policy.

Users should direct any enquiries to the Customer that operates the online forum.  Customers should direct any complaints, concerns or questions regarding Community Sift’s compliance in writing to the Privacy Officer.

Contact information for Community Sift’s Privacy Officer:

Privacy Office

500-554 Leon Ave
Kelowna, BC, Canada V1Y 6J6
email: privacy@twohat.co
Tel: 1-855-407-0889 FREE

We may designate another individual other than the Privacy Officer as the person to contact for any requests related to this Privacy Policy by updating the contact information in policy.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time.  We will post all changes to this Privacy Policy on this page and will indicate at the top of the page the modified policy’s effective date.  If we make any material changes to this Privacy Policy, we may take additional measures to notify you and/or gain your prior consent.  Your continued use of the Services after such changes are made will acknowledge your agreement to any and all changes.

 

 

 

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