2. About this PolicyThis Policy sets out the essential details relating to your personal data relationship with iSAW Foundation. The Policy applies to all iSAW services and any associated services (referred to as the 'iSAW Service'). The terms governing your use of the iSAW Service are defined in our Terms and Conditions of Use (the "Terms and Conditions of Use"). From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy. The aim of this Policy is to:

1. Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
2. Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the iSAW Service; and
3. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 12 'How to contact us' below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the iSAW Service.

3. Your rights and your preferences: Giving you choice and control The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

• Right of access - the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to erasure - the right to request that we delete your personal data;
• Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object -
  • the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
  • the right to object to your personal data being processed for direct marketing purposes;
• Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service; and
• Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If you have any questions about your privacy, your rights, or how to exercise them, please contact us using the 'Contact Us' form on our website www.isaw.org. If you have concerns around our processing of your personal data, we hope you will continue to work with us to resolve them. However, you can also contact and have the right to lodge a complaint with your local Data Protection Authority.

4. Personal data we collect from you We have set out in the tables below the categories of personal data we collect and use about you and how we collect it: The table below describes personal data collected when you sign up for the iSAW Service:

Categories of personal data

Description of category

User Data

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the iSAW Service. Depending on the type of iSAW Service plan you sign up for, this may include your username, email address, phone number, birth date, gender, street address, and country. Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with additional personal data in order to make your account more personalized.

The table below describes personal data collected through your use of the iSAW Service:

Categories of personal data	Description of category
User Data	This is the personal data that is collected about you when you’re accessing and/or using the iSAW Service, including: Information about your type of iSAW Service plan. Information about your interactions with the iSAW Service such as your search queries (including the date and time of any requests you make), , your browsing history, and your interactions with the iSAW Service, content, other iSAW users. This also may include details of your use of third party applications in connection with the iSAW Service. Inferences drawn about your interests and preferences based on your usage of the iSAW Service. User Content (as defined in the Terms and Conditions of Use) you post to iSAW, such as photos, and interactions with the iSAW Customer Service team. Please note that we will only access your camera or photos from your device if you give us permission to do so, and we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your device’s photo library or camera roll. Certain technical data, which may include: URL information; online identifiers including cookie data and IP addresses; information about the types of devices you are using such as unique device IDs, network connection type (e.g. wifi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and iSAW application version; your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to comply with geographic requirements in our licensing agreements.
Plan Verification Data	For users of certain plans, we may use a third party mapping application (such as Google Maps) and/or your device’s location service to help you verify your address. This data is collected for the sole purpose of verifying eligibility and is not used for advertising or any other purpose.

The table below describes personal data that you choose to give us that enables us to provide you with additional features/functionality

Categories of personal data	Description of category
Voice Data	If voice features are available in your market, we collect your voice data with your permission to provide you with additional features and functionalities, such as interacting with the iSAW Service with your voice.
Payment and Purchase Data	We may collect certain personal data if you sign up for a Trial or purchase any of our Paid Subscriptions (as defined in the Terms and Conditions of Use) or make other purchases through the iSAW Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as: Name; Date of birth; Credit or debit card type, expiration date, and certain digits of your card number; Postal code; Mobile phone number; and Details of your purchase and payment history.
Contests, Surveys and Sweepstakes Data	When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.

The table below describes personal data collected from third party sources We collect personal data about you from various third parties. These third party sources vary over time and include the following:

Categories of personal data	Description of category
Authentication partners	If you register for or log into our services using third party credentials (e.g. Facebook, Linkedin), we will import your information from such third party to help create your account with us.
Technical service partners	We work with technical service partners that provide us with certain data, such as mapping IP addresses to non-precise location data (e.g., city, state), to enable us to provide the iSAW Service, content, and features.
Payment partners	If you choose to pay for a service or feature by invoice, we may receive data from our payment partners to enable us to send you invoices, process your payment and provide you with what you’ve purchased.
Advertisers and other advertising partners	We may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.

5. What we use your personal data for When you use or interact with the iSAW Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 4 'Personal data we collect from you' used for these purposes:

Description of why iSAW processes your personal data (‘processing purpose’)	Legal Basis for the processing purpose	Categories of personal data used by iSAW for the processing purpose
To provide and personalize the iSAW Service.	Performance of a Contract Legitimate Interest Consent	User Data Usage Data Payment and Purchase Data Plan Verification Data Voice Data
To understand, diagnose, troubleshoot, and fix issues with the iSAW Service.	Performance of a Contract Legitimate Interest	User Data Usage Data
To evaluate and develop new features, technologies, and improvements to the iSAW Service.	Legitimate Interest Consent	User Data Usage Data Voice Data
For marketing, promotion, and advertising purposes.	Legitimate Interest Consent	User Data Usage Data Voice Data
To comply with legal obligations and law enforcement requests.	Compliance with legal obligations Legitimate interest	User Data Usage Data Payment and Purchase Data Plan Verification Data Voice Data Contests, Surveys and Sweepstakes Data
To fulfill contractual obligations with third parties, for example licensing agreements and to take appropriate action with respect to reports of intellectual property infringement and inappropriate content.	Legitimate interest	User Data Usage Data Payment and Purchase Data
To establish, exercise, or defend legal claims.	Legitimate interest	User Data Usage Data Payment and Purchase Data Plan Verification Data Voice Data Contests, Surveys and Sweepstakes Data
To conduct business planning, reporting, and forecasting.	Legitimate interest	User Data Usage Data Payment and Purchase Data
To process your payment.	Performance of a Contract Compliance with legal obligations	User Data Payment and Purchase Data
To detect fraud, including fraudulent payments and fraudulent use of the iSAW Service.	Performance of a Contract Compliance with legal obligations Legitimate Interest	User Data Usage Data Payment and Purchase Data Plan Verification Data
To conduct research, contests, surveys, and sweepstakes.	Performance of a Contract Legitimate Interest Consent	User Data Usage Data Contests, Surveys and Sweepstakes Data

If you require further information about the balancing test that iSAW has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 12 'How to contact us' for further details on how to contact us.

6. Sharing your personal data We have set out the categories of recipients of the personal data collected or generated through your use of the iSAW Service. Available information to other iSAW members The following personal data will always be publicly available on the iSAW Service: your name and/or username, profile picture, who you follow and who follows you on the iSAW Service. Personal data you may choose to share The following personal data will only be shared with the categories of recipients outlined in the table below if:

• you choose to make use of a specific iSAW Service feature where sharing of particular personal data is required for the proper use of the iSAW Service feature; or
• you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the iSAW Service or authorizing iSAW through a presented consent mechanism.

Categories of Recipients	Reason for sharing
Your iSAW followers	There may be times when you want us to share information about your use of the iSAW Service with other iSAW users known as ‘Your iSAW Followers’.

Learn more about how to manage notifications, your publicly available information, and what you share with others in Section 3 'Your rights and your preferences: Giving you choice and control' of this Policy Information we may share

Categories of Recipients	Reason for sharing
Service providers	We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we have hired to provide customer service support, operate the technical infrastructure that we need to provide the iSAW Service, assist in protecting and securing our systems and services, and help market iSAW’s own products and services as well as partner products, services, events, and co-branded promotions in which iSAW is involved.
Payment processors	We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.
Advertising partners	We work with advertising partners to enable us to customize the advertising content you may receive on the iSAW Service. These partners help us deliver more relevant ads and promotional messages to you, which may include interest based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the iSAW Service. We and our advertising partners may process certain personal data to help iSAW understand your interests or preferences so that we can deliver advertisements that are more relevant to you.
iSAW partners	Depending on how you sign up for the iSAW Service (e.g. through a third party service or a mobile provider), we share your iSAW username or other User Data as necessary to enable your account. We may also share personal data with that third party about your use of the iSAW Service, such as whether and to what extent you have used the offer, activated a iSAW account, or actively used the iSAW Service.
Academic researchers	We will share your personal data for activities such as statistical analysis and academic study but only in a pseudonymized format.
Other iSAW group companies	We will share your personal data with other iSAW group companies to carry out our daily business operations and to enable us to maintain and provide the iSAW Service to you.
Law enforcement and data protection authorities	We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business	We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, iSAW will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

7. Data retention and deletion We keep your personal data only as long as necessary to provide you with the iSAW Service and for legitimate and essential business purposes, such as maintaining the performance of the iSAW Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the iSAW Service. If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

• If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
• Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
• Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

8. Transfer to other countries iSAW shares your personal data globally with iSAW group companies in order to carry out the activities specified in this Policy. iSAW may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country. Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances iSAW shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission. For further details of the security measures we use to protect your personal data, please see Section 10 'Keeping your personal data safe' of this Policy.

9. Links We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties' privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the iSAW Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

10. Keeping your personal data safeWe are committed to protecting our users' personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems. Your password protects your user account, so we encourage you to use a strong password that is unique to your iSAW account, never share your password with anyone, limit access to your computer and browser, and log out after having used the iSAW Service.

11. Changes to this Policy We may occasionally make changes to this Policy. When we make material changes to this Policy, we'll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the iSAW Service or by sending you an email and/or a device notification. We may notify you in advance. Please, therefore, make sure you read any such notice carefully. If you want to find out more about this Policy and how iSAW uses your personal data, please reach out to us via the ‘Contact Us’ form at www.isaw.org

12. How to contact us. Thank you for reading our Policy. If you have any questions about this Policy, please contact us by using the 'Contact Us' form on our website www.isaw.org, or emailing info@isaw.org, or by writing to us at the following address:
iSAW Foundation.
PO Box 2577, Chandler, Arizona 85244, United States of America