Privacy Policy

‍Last Updated: September 16, 2024

This Privacy Notice applies to the projectliberty.io website and other products and services, including websites, mobile apps, registration forms, and any other digital properties that link to or display this Privacy Notice.  To make this Privacy Notice easier to read, such websites, mobile applications, and other offerings are collectively called the “Services.” The Services do not include, and this Privacy Notice does not apply to, Frequency Access, or any other products or services made available via Frequency Access.

This site is operated by Project Liberty LLC, a part of the Project Liberty initiative to transform how the Internet works, who owns and controls personal information, and who benefits from the digital economy (collectively, “Project Liberty,” “we,” “us” or “our”).

This Privacy Notice describes the types of personal information collected in connection with your use of the Services, how the personal information is processed, and to whom the personal information is disclosed. This Privacy Notice also describes how you can exercise your rights and choices with respect to your personal information.

**Please hyperlink each header in this table of contents to the relevant section below so that users can jump to the right section.

1. UPDATES TO THIS PRIVACY NOTICE

2. PERSONAL INFORMATION WE COLLECT

3. HOW WE USE YOUR PERSONAL INFORMATION

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

5. YOUR PRIVACY CHOICES AND RIGHTS

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

7. RETENTION OF PERSONAL INFORMATION

8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

9. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

10. CHILDREN’S INFORMATION

11. THIRD-PARTY WEBSITES/APPLICATIONS

12. CONTACT US

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on the Services and/or may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Your Communications with Us. We may collect personal information, such as your name, email address, or phone number when you contact us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., commenting functionalities, petitions, People’s Bid for TikTok pledge of support and letter writing functionalities, forums, blogs, and social media pages). If you choose to display your name or provide content on the Services, you understand that your name and other identifiable information in your content will be publicly viewable. Any information you provide using the public sharing features of the Services will be considered public. Please exercise care when deciding what to share.  

• Information about Yourself and Others. You may choose to submit content (in photo, video or audio format) through our Services when you share your perspective on the state of social, the People’s Bid for TikTok and other related topics. This content may include personal information about you or others. If you provide information about others, you acknowledge and agree that you have the consent and authority of the other parties for us to access, disclose and use the relevant personal information. We may share and publish your and others’ submitted information on the Services and on Third-Party Services (as defined below), including social media.

• Conferences and Other Events. We may collect personal information from individuals when we attend or host conferences and other events.

• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, items that you search for via the Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

• Cookie Policy (and Other Technologies). We, as well as third parties that provide content or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Some of the Technologies we use include:

• Matomo Analytics.  We use Matomo Analytics’ analytics cookies to gain a better understanding of the traffic to the Services – things like how many people visit our website, how much time they spend on our website and which pages of our website they visit. To learn more about Matomo Analytics and its use of cookies, please see Matomo Analytics’ privacy policy.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

C. Personal Information Collected from Other Sources

Third Parties. We may collect personal information from third parties. For example, if you access our Services through a Third-Party Service (as defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about other individuals through a referral or sharing feature.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your personal information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Sending you information that you requested or agreed to receive, such as newsletters;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative Purposes

We use your personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development, network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Carrying out analytics;
• Developing new products and services;
• Creating de-identified and/or aggregated information;
• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

c. Marketing our Services

We may use personal information to provide you with marketing about our Services. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

(this contact us should hyperlink  to Section 12 below.)

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Other Users and Third Parties You Share or Interact With. The Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services and the general public).

• Third-Party Services You Share or Interact With. The Services may allow you to share information or interact with third-party services (each a “Third-Party Service”).

If you share information or interact with a Third-Party Service, the information collected by the Third-Party Service will also be subject to the Third-Party Service’s privacy policy.

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer initiatives, products or services.

• Affiliates. We may share your personal information with our corporate affiliates.

• The Project Liberty Institute. We may share your personal information with Project Liberty Institute with whom we may jointly offer initiatives, events or services.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to this Privacy Notice).

• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

(this contact us should hyperlink  to Section 12 below.)

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”);

• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information;

• Request Restriction of or Object to our processing of your personal information; and

• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

(this contact us should hyperlink  to Section 12 below.)

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK GDPR.

Our processing of your personal information may be supported by one or more of the following legal bases:

• Performance of a Contract: We may need to process your personal information to perform our contract with you.

• Legitimate Interest: We may process your personal information to further its legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms.

• Consent: In some cases, we may also rely on your consent to process your personal information.

• Compliance with our Legal Obligations: We may process your personal information to comply with our legal obligations.

9. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

We do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in “Contact Us” below.

(this contact us should hyperlink  to Section 12 below.)

10. CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

(this contact us should hyperlink  to Section 12 below.)

11. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. CONTACT US

Project Liberty is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: privacy@projectliberty.io.