(Last Revised July 16, 2018)
- Information We Collect
- Our Legal Basis for Using Your Information
- Cookies and Other Technologies
- How We Use Your Information
- How We Share Your Information
- Do Not Track
- Your California Privacy Rights.
- Information Transfers and Storage
- Your Rights Regarding Your Information
- Data Retention
- Third Party Sites, Content, and Resources
- Contact Us
I. Information We Collect
Information You Provide to Us. When you use our Sites, such as when you subscribe to our newsletter, register for an account, submit an award nomination, or apply for a grant, we, or our service providers (acting on our behalf), collect “personal information” (which is information that relates to an identifiable natural person) that you provide to us, such as your first and last name, email address, telephone number(s) and postal address.
Information We Collect from You Automatically. When you use the Sites, we will also collect information about your use of the Sites and the device you use to access the Sites (e.g., your computer, tablet, phone, etc.) such as your IP address and country location, browser information (including browser type, capabilities, and language), operating system, the date and time you accessed the Sites, and website usage information, including the paths taken as you move from one webpage to another webpage (i.e., your “click stream” activity).
II. Our Legal Basis for Using Your Information
If you are accessing our Sites in the European Economic Area (“EEA”), then applicable law requires us to ensure that we only process your personal information where we have a legal basis to do so. We will only process your personal information where at least one of the following applies:
- If it is in our legitimate interest or the legitimate interest of others to use your personal information. For example, it is in our legitimate interest to use your personal information to improve our Sites and enforce our legal rights. If you would like further information about how we decide when a particular use is in our legitimate interest, you may contact us using the contact details set out below.
- We need to use your personal information to perform our responsibilities under a contract we have with you (including, for example, processing your award nomination or grant application).
- Sometimes we may ask for your consent to use certain types of personal information (e.g., by asking you to tick an online box). In these circumstances, your consent will be our legal basis for processing your personal information. If you have provided consent, you may withdraw it at any time. You may do this by “opting out” where we give you the opportunity to do so, or by contacting us using the contact details below.
III. Cookies and Other Technologies
Cookies. Cookies are text files placed in your computer’s browser. A cookie can be used to uniquely identify your computer and may contain information about your website interactions. We use certain cookies and other similar analytics technologies offered by our third-party service providers to make the Sites available, understand your use of the Sites, customize the content offered to you on the Sites and to deliver relevant advertising to you.
Web Beacons. The Sites also contain “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
Mobile Device Identifiers. If you access the Sites via a mobile app, we use additional identifiers, such as the advertising ID provided by Apple or Android, for similar purposes.
We use these technologies for the following purposes:
- Social Media. Our Site includes social media cookies, including those that enable users who are logged in to a social media platform to share content via that platform.
- Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use a tool called “Google Analytics” to collect information about use of the Sites. Google Analytics collects information such as how often users visit the Sites, what pages they visit, and what other Sites they visited prior to coming to one of the Sites. We use the information we get from Google Analytics to improve the Sites. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the sites, the cookie cannot be used by anyone but Google. To opt-out of Google Analytics, please use Google’s opt-out tool: https://tools.google.com/dlpage/gaoptout.
To learn how to reduce the number of cookies you receive or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser. You can also learn more about cookies by visiting https://ico.org.uk/for-the-public/online/cookies, which includes additional useful information on cookies and how to block cookies using different types of browsers.
IV. How We Use Your Information
We (and our service providers) will use your personal information for the following purposes:
- To provide the features and functionality of the Sites to you.
- To process your newsletter subscription, grant application or award nomination entry.
- To identify you as the sender of, and to process, your emails.
- To respond to questions and comments.
- To improve, enhance, and tailor the Sites for you (for example by providing content or features that match your interests), and to improve and enhance the overall experience for all users of the Sites.
- To send you emails or postal mail about special offers or promotions, if you have consented to this.
We may anonymize your information (for example by aggregating it with other individuals’ personal information so that it no longer identifies you) and use it for other purposes in anonymized form.
V. How We Share Your Information
We will share your personal information for the following purposes:
- Business transfers: If a third party acquires all or substantially all of our assets, your personal information, and any other information that we have collected in connection with the Sites, will be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered part of our assets and may be sold or transferred to third parties.
- Service providers: We use third parties to perform services on our behalf, such as application processing, email delivery, and website maintenance. These service providers will access your personal information as necessary for them to perform their duties. For example, we will share your grant application with our consultant, who evaluates applications and makes recommendations to our Trustees, board of directors and members.
The Sites are intended for use only by persons who are at least 18 years of age. We do not and will not knowingly collect personal information from anyone whom we know to be under 16 years of age. If you are under the age of 16, you may not use the Sites unless your parent or guardian has provided us with their consent for your use of these Sites.
VII. Do Not Track
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
VIII. Your California Privacy Rights
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). At this time, we do not share personally identifiable information with third parties for their direct marketing purposes. However, if we do so in the future, we will give you choices prior to sharing your information with third parties for their direct marketing purposes. If you are a California resident and you have questions about our practices and your choices regarding sharing of information with third parties for their direct marketing purposes, please contact us using the information below.
IX. Information Transfers and Storage
If you are in a country other than the United States of America, you should be aware that the data that we collect from you will be transferred to and stored in the USA. The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country.
Yangaroo, one of our service providers, processes data associated with award nominations in Canada.
In an effort to safeguard individual privacy, we will only transfer personal information from the EEA to another country if one of the following applies: the receiving country has data protection laws that mandate an adequate level of protection for the rights of data subjects; we have entered into an agreement using standard contract clauses (approved by the European Commission or a data protection authority) with our service provider regarding the transfer; the service provider that transfers the data is certified under the EU-US Privacy Shield Framework; or you give your express consent to the transfer.
If you have any questions about our transfer of personal information to other countries, or would like further information, please contact us using the details below.
X. Your Rights Regarding Your Information
If you are in the EEA, you have certain additional rights in relation to your personal information. If you would like further information in relation to these or would like to exercise them, please contact us using the contact details below at any time. You have the right to request that we:
- provide access to any personal information we hold about you;
- update any of your personal information which is out of date or incorrect;
- delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- prevent the processing of your personal information for direct-marketing purposes;
- provide your personal information to a third-party provider of services;
- provide you with a copy of any personal information which we hold about you; or
- consider any valid objections which you have to our use of your personal information.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
You may unsubscribe from our newsletter or ask us to stop using your personal information for advertising or marketing purposes at any time. If you wish to do this, please follow the removal instructions in any communication you receive or contact us using the information below.
XI. Data Retention
We will generally store information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law. For more information, contact us using the details below.
XII. Third Party Sites, Content, and Resources
We will take reasonable steps to protect the security and integrity of your personal information. However, please note that we cannot guarantee that any information transmitted through the Internet or stored on our system or otherwise in our care will be absolutely safe from prohibited intrusion by others. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after the transmission or storage of your personal information.
XV. Contact Us
If you have any questions or comments regarding our privacy practices, you may contact us using the following details:
Post: Hollywood Foreign Press Association
646 N. Robertson Blvd.
West Hollywood, CA 90069
Attn: General Counsel
In addition, if you are in the EEA and you have any complaints about how we use your Personal Information, you have the right to lodge a complaint with the data protection authority in your country or seek a remedy through local courts if you believe your rights have been breached. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.