2 February, 2012
As used in this policy, “personally-identifying information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number or email address.
As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number or email address.
a. Openness Principles
P2PU is an open and transparent organization. In that spirit, we share as much information as possible about our products, services, operations, and associations. Users who interact with P2PU Web sites should therefore understand and be aware that by posting or otherwise providing publicly any personally-identifying information to P2PU or through a P2PU service, you are making such information publicly available through the Internet, and it is possible that your personally-identifying information may be viewed or even archived by anyone. There are three exceptions to this broad principle, explained in (d), below.
b. Visitors to P2PU Web Sites
P2PU’s purpose in collecting this information is to better understand how P2PU’s visitors use its Web sites. To that end, P2PU may share such information with its employees, contractors, volunteers, and its subsidiaries and related organizations. P2PU may also release such information about visitors (e.g., by publishing a report on Web site usage trends).
c. Community Members
Certain members of the P2PU community (course organizers, participants, etc.) choose to interact with P2PU in ways that require P2PU and others to know more about them. The amount and type of information that P2PU gathers from those members depends on the nature of the interaction. For example, certain features are only available to logged-in users. P2PU asks course leaders and participants to create user profiles, which may include photographs and personal descriptions. Members who are registered and sign in to the P2PU website are able to contact members through their profiles. Contact information such as email addresses are not publicly available on the P2PU Web site, however if a user sends email through the website, the message contains the sender’s email address, which will thereby be revealed to the recipient.
Course leaders and participants in the same course are likely to obtain personally-identifying information for the purposes of supporting and improving collaboration and communication in the course itself. P2PU is not responsible for the disclosure of personally-identifying information that is voluntarily revealed when participating in a course, nor is it responsible for the actions of any third party (such as course organizers or participants) with respect to such personally-identifying information. Certain features of the P2PU service may limit course capacity or access to a limited number of users, however, such limitations are not intended to limit the accessibility of course materials and related discussions, and P2PU may make any course materials or discussions more or less publicly accessible at any time without notice.
As a general rule, users should assume that that any personally-identifying information provided through P2PU’s Web sites will be publicly accessible to other users of the P2PU service as well as anyone else that accesses the P2PU service such as but not limited to web crawling computer programs operated by third-party search engine operators that may then include such materials in search engine search results. As an exception, P2PU does not intend to make publicly available:
- information that is used to authenticate users the publication of which would compromise the security of P2PU’s Web sites (e.g., passwords);
- information that it specifically states at the time of collection to maintain in confidence; and
- financial account information gathered in connection with commercial transactions (i.e., transactions involving money such as donations to P2PU).
e. Interactive Product Features
Certain P2PU products or services may contain features that report, or that permit users to report, the user’s usage patterns to P2PU. The reports generated by these features typically include both non-personally-identifying information such as the configuration of the user’s computer and personally-identifying information such as usernames and IP addresses. P2PU may analyze the information provided by these interactive product features to develop a better understanding of how its users interact with each other and the P2PU service, how they participate in learning activities and what skills and competencies they develop and demonstrate.
f. Protection and Disclosure of Certain Personally-Identifying Information
Where P2PU has collected personally-identifying information subject to one of the three exceptions described in the Community Members section, above, it discloses that information only to those of its employees, volunteers, contractors and its subsidiaries and related organizations that need to know that information in order to process it on P2PU’s behalf and that have agreed not to disclose it to others. Some of those employees, volunteers, contractors and subsidiaries and related organizations may be located outside of a visitor’s home country; by using P2PU’s Web sites, the visitor consents to the transfer of his/her information to them. P2PU does not rent or sell such information to anyone. Other than to its employees, contractors or its subsidiaries and related organizations, as described above, P2PU discloses such information only when required to do so by law, or when P2PU believes in good faith that disclosure is reasonably necessary to protect the property or rights of P2PU, members of the P2PU community, or the public at large.
g. Updating of Personally-Identifying Information
P2PU permits users to update and correct some of their personally-identifying information as maintained by P2PU through the P2PU website. To do so, users should look for links or contact information available on whichever P2PU Web sites store the relevant information, or contact P2PU by email at email@example.com. Users are permitted to deactivate their profile, however, contributions to the P2PU Web site will not be removed when the profile is deactivated.
P2PU’s web sites are not directed at children under the age of 13. Consistent with the United States Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally-identifying information from anyone under the age of 13 without requiring parental consent. If we learn that personally-identifying information has been collected from a user under 13 years of age on or through the P2PU website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has provided P2PU with personally-identifying information, please contact P2PU at firstname.lastname@example.org to have that child’s information deleted.
i. Cookies and Clear GIFs
Clear GIFs. Clear GIFs (also known as web beacons) are often used in combination with cookies to help web site operators understand how visitors interact with their websites. A clear GIF is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email. The use of a clear GIF allows the site to measure the actions of the visitor opening the page that contains the clear GIF. It makes it easier to follow and record the activities of a recognized browser, such as the path of pages visited at a website.
In the event of a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we reserve the right to transfer all of the information you give to us, including email addresses, to that entity. We will use reasonable efforts to notify registered users of such a transfer (by a posting on our home page, or by email to your email address that was provided to us, as chosen by us in our discretion).
WE CANNOT GUARANTEE THAT ANY SECURITY MEASURES WE MAY EMPLOY WILL PREVENT UNAUTHORIZED PERSONS FROM ILLEGALLY ACCESSING OR OBTAINING THE PERSONALLY-IDENTIFYING INFORMATION YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE P2PU SERVICE. If we learn of a security breach, we will notify you, as required by applicable law. By using the P2PU website or providing personally-identifying information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the P2PU website. If a security systems breach occurs, we may post a notice on our homepage (www.p2pu.org), or elsewhere on the P2PU website and may send email to you at the email address you have provided to us.
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