Privacy Policy

This Privacy Policy describes how Edera L3C (which operates the National Coordination Center) collects, uses, or discloses personal information we receive through our website (https://edera.com/) or through any mobile application or other online or offline services we offer (collectively, the “Services”). This policy also describes your choices about the collection and use of your information. Note that if you have a business relationship with us, the contractual terms of that relationship will control in the event of any conflict.

Please read the Privacy Policy carefully before you start to use the Services. By using the Services, you agree to be bound and abide by our posted Terms of Use (“Terms”) and this Privacy Policy. Your right to access or use the Services is terminated if you decline or violate these Terms or our Privacy Policy. Please see Sections 10-12 of our Terms regarding your legal rights in any dispute involving our Services.

1. HOW WE COLLECT INFORMATION

We may collect information about you by various means, including:

• From you, through our Services both online (e.g., website) and offline (e.g., at events);
• From organizations that we partner with;
• By combining information from different sources, including online and offline data; and
• From other sources and social media platforms that you may use to engage with us.

2. TYPES OF INFORMATION THAT WE COLLECT

We may collect the following categories of information:

• Profile and subscription information, such as your name, mailing address, email address, phone number, and usage and subscription preferences (including user credentials if we provide any access-restricted Services);
• Survey information in response to questions that we may send you through the Services, including for research purposes or to improve our Services;
• User content that you may provide to us via the Services (e.g., articles, interviews, social media content, testimonials, and other materials) along with any pictures and information that you provide about yourself and the content;
• Communications between you and us, such as via email, web form, phone, or other channels;
• Offline activity that you engage in with us, such as when attending our events; and
• Online User Activity described in the next section.

If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and you permit us to use the information in accordance with this Privacy Policy.

3. ONLINE USER ACTIVITY, COOKIES, AND INFORMATION COLLECTED BY OTHER AUTOMATED MEANS

Cookies are a commonly used web technology that allow websites to store and retrieve certain information on a user’s system, and track users’ online activities. We, our service providers, and our business partners may collect information about your use of our websites and mobile apps by such automated means, including (but not limited to) cookies, pixels, and other similar technologies. Cookies and these other technologies can help us automatically identify you when you return to our Services. Cookies help us review website traffic patterns and improve the website, as well as determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use any Services we provide, the information that we may collect by automated means includes for example:

• Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number)
• Location information where you choose to provide us with information about your device’s location.

If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information obtained via cookies with website technology vendors. Because there is not yet a consensus on how organizations should respond to web browser-based, do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Note that certain advertising partners we use may be able to collect information about users’ online activities over time and across third-party websites.

4. HOW WE USE THE INFORMATION THAT WE COLLECT

We may use the information that we obtain about you for purposes allowed by applicable laws, including:

• Provide our Services to you and respond to your inquiries and other communications;
• Tailor the content that we display to you in our Services and communications, including advertising, offer opportunities, and information that we believe may be of interest to you;
• Operate, evaluate, and improve our Services, including to diagnose or fix technology problems;
• Monitor the performance of our Services (including metrics such as total number of visitors, traffic and demographic patterns), as well as analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Provide you with administrative notices, such as to inform you about changes to this Privacy Policy and our Terms; and
• Comply with and enforce applicable legal requirements, industry standards, our policies, and our contractual rights as needed.

We may also use or share information in an anonymized or aggregate manner for many purposes, such as research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.

5. ONLINE ADVERTISING

You may see us promoted by other organizations, on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our organization may be displayed or promoted, and if you believe that Edera is featured in venues that are inappropriate or offensive, please contact us.

We may serve advertisements, and allow third parties to serve advertisements, through our Services. Advertisements served through our Services may be targeted to users who fit a certain general profile category, which may be inferred from information that you provide to us or, based on your website usage patterns, or based on your activity on other websites or online services as may be available to the ad networks.

6. HOW WE SHARE YOUR INFORMATION

We will not disclose your personal information to third parties without your consent, except in the following circumstances:

• We may share, in our reasonable discretion, basic contact information with organizations we partner with for various purposes; for example, Edera partners such as academic institutions;
• If you voluntarily share or submit any User Content including contact information or commentary for public posting through our Services, or link it to any social media platforms, that post (and any content or information associated with it) may become available to the public. See our Terms for more information about User Content;
• We may share your information as permitted by law, including for example, with our service providers that we believe need the information to perform a technology, organizational, or other professional function for us (examples include IT services, maintenance and hosting of our Services, marketing and data analytics partners, and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf;
• We also may disclose information about you (i) if we are required to do so by law or legal process; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, users, or the public;
• We reserve the right to transfer the information we maintain in the event of a major organizational transaction affecting all or a portion of our organization or assets. If we engage in such a transaction, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy;
• We may, from time to time, contact you on behalf of third parties about a particular offering or opportunity that may be of interest to you. In such cases, your contact information is not transferred to the third party, but rather we send you a communication on their behalf.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us and applicable law.

7. YOUR PRIVACY CHOICES

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Informational Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, opportunities to participate in our activities, or other general communications. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive certain informational emails from us by clicking on the unsubscribe link in the emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-informational email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
• Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites and mobile apps may not function correctly.
• Information Requests: If you have a particular request with respect to personal information that we maintain about you, please contact us as directed below and where required by applicable law or otherwise in our reasonable discretion we will endeavor to address your request.

8. LINKS TO OTHER WEBSITES AND THIRD–PARTY CONTENT

Our Services may contain links to other websites or apps. This can include social media integrations and our various third-party partners. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.

9. HOW WE PROTECT INFORMATION

We endeavor to maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via email or conspicuous posting on the Services, you agree to accept notice in that form.

10. CHILDREN

The Services are intended for use only by persons over the age of 13. We do not seek to collect information about children under the age of 13 and aim to delete such information if discovered.

11. INTERNATIONAL DATA TRANSFERS AND USE

Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States.

12. UPDATES TO OUR PRIVACY POLICY

We may revise the information on the Services or otherwise change or update the Services, including this Privacy Policy. If we make changes to this Privacy Policy, we will post notice of the modifications to the Privacy Policy on this page. Changes will become effective when posted. We encourage you to periodically check our Privacy Policy to see if there have been any changes of interest to you. Your continued use of the Services after an update to our Privacy Policy constitutes agreement to the policy as revised.

13. CONTACTING US

If you have questions, comments, or concerns about this Privacy Policy, our privacy practices, or if you would like us to update information or preferences that you provided to us, please contact us by email to [email protected] or by phone to 202.867.7258.

This Privacy Policy was last updated on October 6, 2022.