NABU GLOBAL INC. PRIVACY POLICY

Last Updated and Effective as of November 26, 2024

NABU Global, Inc. d/b/a NABU.org (“NABU,” “Company,” “we,” “our,” or “us”) understands that privacy is important to our users. Protecting your private information is our priority. The Privacy Policy below discloses our practices regarding information collection and usage, including www.nabu.org (the “Website”), the NABU iOS and Android apps (the “App”), and any other services provided by us or our affiliates (collectively, the “Services”).

OVERVIEW:

This Privacy Policy describes our information collection, usage, and sharing practices, including our personal information collection, usage and sharing practices.

We collect information when it is voluntarily provided by you (see Information We Collect; How We Collect It; How We Use It).

We automatically collect information from users of our Services for user authentication, device security, and for analytical purposes (see Information We Collect; How We Collect It; How We Use It and Cookies and Tracking Technologies).

If you are a resident of the European Economic Area (“EEA”), Switzerland, or the United Kingdom, you can access, delete and control certain uses of your personal information (see Additional European Disclosures).

We will not use or share your personal information with anyone except as described in this Privacy Policy or as otherwise authorized by you or required or permitted by law.

By accessing or using the Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, you should not use the Services or otherwise provide us with personal information. If you have questions, you can always contact us using the information in the section below titled Contact.

Our Platform is provided from the United States of America and all servers that make it available reside in the United States of America. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States.

INFORMATION WE COLLECT; HOW WE COLLECT IT; HOW WE USE IT:

We collect certain information that specifically identifies, describes, or references a particular consumer (“personal information”). We collect personal information, including:

● Registration Information. When you create an account on our App, you will be asked to provide your name, email address, phone number, user name, and a password.

● Communication Information. When you contact us, sign up for our newsletter, or sign up to be a member of our Content Action & Advisory Board, you provide us with your name, email address and any other information you choose to provide over such communication, including your geographic location and information about your query.

● Purchase information. When you make a purchase or donation through our Website, you provide us with your name, email address, and credit card information. Your archived credit card information is maintained by our third-party payment provider in a secure and safe environment.

● Device and online identifiers and related information. When you use our Website or App, we or our third-party service providers may automatically and indirectly collect data about your device. This includes internet protocol (IP) address, device name, device operating system type and version, data collected from cookies, beacons, and pixel tags, and similar unique identifiers. When you use our App, we may generate a device ID to associate with your device.

We may collect, use, and/or disclose your personal information for the following business or commercial purposes:

● To create, maintain, customize, and secure your account with us, and to personalize your Website and App experience.

● To operate the Services and to provide you with any specific services you have requested.

● To process and fulfill your order, and to notify you of your order status.

● To collect or process donations.

● For testing, research, analysis, and product development, including to develop and improve our Services.

● To provide you advertising for products, services, and other charitable organizations that may be of interest to you.

● To provide you with support and to respond to your direct inquiries, including to investigate and address your concerns and monitor and improve our responses.

● To deliver content and product and service offerings relevant to your interests.

● To administer promotions and surveys.

● To provide opportunities to further engage with the Services through advocacy and fundraising campaigns.

● To help maintain the safety, security, and integrity of our Services, databases, and other technology assets.

● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and fulfillment.

● To comply with non-profit or charity reporting or registration requirements.

● To respond to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation.

● To investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for the Services.

● To transfer your information in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated.

● For any other purpose to which you consent.

We may permit our vendors and subcontractors to access your information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use any personal information for their own benefit. Please note that if you consent to additional uses of your information, we may use your information in a manner consistent with that consent.

If you choose to share content with the NABU community through our Services, the shared content may be publicly accessible. If you do not want to share content publicly, you can use your privacy settings to limit sharing. You may delete some content that you shared, but some interactive shared content may persist in association with your registered user account, even after your account is terminated. Therefore, you should keep this in mind when participating in shared content activity through our Services.

Please be advised that “non-personal information” (i.e., information that does not personally identify you, such as aggregated and/or anonymized data) may be shared with any number of parties and may be used in any manner consistent with applicable law. Without limiting the forgoing, as used herein, personal information does not include information that is lawfully made available from federal, state, or local government records, or de-identified, anonymized, or aggregated information.

OTHER WEBSITES AND SOCIAL NETWORKING SERVICES:

As a convenience to you, we may provide links to third-party websites, apps, or services from within the Website. We are not responsible for the privacy practices or content of these third-party sites, and by providing a link, we are not endorsing or promoting such third-party sites. We encourage you to review the privacy policies of every third-party site or service that you visit or use, including those third parties with whom you interact through our Services.

The Website may also integrate with social networking services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, social network, or otherwise online may be viewed and used by others.

FUNDRAISING AND MARKETING OUTREACH:

As is customary in the nonprofit world, we may send requests to support the NABU library to people who have expressed interest in the library’s programs or services. In order to ensure the most efficient use of our resources, we retain third-party vendors to make sure the contact information we have for our users is current and to determine which users are most likely to provide support. We do not rent or sell your information but we do share names and postal addresses with other nonprofit cultural organizations. Sharing this information with other reputable charitable organizations is the most cost-effective way to find new users, share program offerings, and identify new donors. We may also use information collected about you to work with third-party marketing vendors to show you ads on third-party websites about library services. We may also use your information to improve our marketing outreach by working with third-party vendors to build models to identify and reach new users online.

COOKIES AND TRACKING TECHNOLOGIES:

We or our third-party service providers may store some information on your device or device hard drive as a “cookie” or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website and Services. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, without limitation, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your IP address, what pages on the Website you visit and what links you clicked on, the region where your device is located, and geo-IP data. We may use cookies to customize your visit to the Website, maintain the efficiency and usefulness of the Website, facilitate your purchasing activity, and for other purposes to make your visit more convenient or to enable us to enhance our Website and Services. For additional information about how the Website uses cookies, please read our Cookie Policy.

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.

DATA SECURITY:

We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide to us. Please note that no data transmission or storage can be guaranteed to be 100% secure due to the inherent open nature of the Internet. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

DATA RETENTION:

We will retain your information for as long as your account or inquiry is active or as needed to provide you with our Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your personal information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your personal information.

INFORMATION RELATING TO CHILDREN:

NABU has developed its Services to be an enjoyable experience for users of all ages, including those under 16 (“Children” or “Child”). However, the Services are designed so that only parents or guardians may enter individually identifiable information. Accordingly, Children may not provide individually identifiable information through the Services, and we do not knowingly collect individually identifiable information from Children. By providing individually identifiable information to us, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so.

We take Children’s privacy seriously and encourage parents to take an active role in protecting their Children’s privacy and online experience at all times. You are expected to keep your account settings secure from Child access, and not to share login information for or related to your account with your Children. Please discuss safe privacy practices with your Children so that they will better understand how to use the Services as intended. If we learn that we have collected or received individually identifiable information from a Child without verification of parental consent, we will delete that information. If you believe we might have any individually identifiable information from or about a Child, please contact us at info@nabu.org.

NABU is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”), a U.S. federal law designed to protect Children online. We may collect and store persistent identifiers (such as cookies or IP addresses) from Children without parental consent for the purpose of supporting the internal operations of the Services or as otherwise permitted under COPPA. Except as otherwise outlined in this Privacy Policy, we do not collect personal information from users of the Services.

OPT-OUTS:

Notifications or Messages: Users have the option to turn off or opt out of notifications or messages. If you wish to no longer receive notifications or messages from us, contact us at info@nabu.org.

Personal Information Opt-Out: If you do not want us to retain or use your personal information, you may withdraw your consent by contacting us at info@nabu.org.

Account Termination: You may request deletion of your Website account by sending an e-mail to info@nabu.org. Please note that some information may remain in our records after deletion of your account.

Cookies: If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personal information from your device without your knowledge.

YOUR CHOICES:

In addition to the choices described herein, NABU also provides all consumers with the right to delete personal information. Specifically, you have the right to request that we delete the personal information that we have collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal information, we may deny your request or may retain certain elements of your personal information if it is necessary for us or our service providers. You may request that we delete your personal information by:

• Emailing us at info@nabu.org

YOUR RIGHTS:

These additional privacy right disclosures provide additional information about our personal information processing practices relating to individual residents of the applicable jurisdictions. Unless otherwise expressly stated, all defined terms in this Privacy Policy retain the same meaning in the disclosures below. The rights, to the extent those rights are applicable set forth below are granted only to the extent they apply and are enforceable in an applicable jurisdiction.

CALIFORNIA “SHINE THE LIGHT”

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at info@nabu.org. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at info@nabu.org.

NEVADA PRIVACY RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at info@nabu.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

ADDITIONAL U.S. STATE PRIVACY RIGHTS

If you are a resident of Colorado, Oregon, Delaware, New Jersey, or another U.S. state that has similar comprehensive privacy legislation (collectively, “Covered States”), you may have specific rights regarding your personal information under: the Colorado Privacy Act, Oregon Consumer Privacy Act, Delaware Personal Data Privacy Act, New Jersey S.B. 332, and similar laws in other U.S. states (collectively, "State Privacy Laws"). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of Covered State and we are acting as a “controller” under State Privacy Laws with respect to your personal information (which is referred to throughout this section as “personal data” for consistency with State Privacy Laws).

The categories of personal data that we process, our purposes for processing your personal data, the categories of personal data that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.

Rights to Your Information

In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:

● Right to know. You may have the right to know whether we process your personal data and to access such personal data. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal data. Oregon residents may obtain a list of the specific third parties to which we have disclosed personal data.

● Right to data portability. You may have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.

● Right to delete. You may have the right to delete personal data that you have provided by or that we have obtained about you. Please note that we may deny such a request if the requested deletion falls under an exception as set forth in the State Privacy Laws.

● Right to correct. You may have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for which we process it.

● Right to opt out. You have the right to opt out of the processing of your personal data for purposes of: (i) targeted advertising; (ii) the sale of personal data; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. However, as of the latest date of the Privacy Policy, we do not conduct any of these activities and have no plans to do so.

● Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:

o Deny you goods or services;

o Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

o Provide you a different level or quality of goods or services; or

o Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Privacy Rights

To exercise any of your rights under State Privacy Laws, or if you have any questions about your privacy rights, you may contact us by:

• Emailing us at info@nabu.org

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify using reasonably commercial efforts that the consumer submitting the request is the same individual about whom we have collected personal information, then we are not required to comply with the request; we may contact you for more information reasonably necessary to authenticate the request, but ultimately we may not be able to meet your request.

Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint

EUROPEAN PRIVACY RIGHTS:

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis:

We will only use your personal data, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where you have consented to a certain use of your personal data.

Where we need to comply with a legal or regulatory obligation.

To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve personal data when we have a good faith belief that doing so is necessary.

Data controller:

NABU is the data controller of all personal data collected through our Services. To contact us, please see the section titled Contact.

If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager can be contacted here: info@nabu.org.

Provision of personal data and failure to provide personal data:

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources:

We do not collect personal data about you through public sources. We may obtain personal data and other information about you through our third-party partners who help us provide our products and services to you.

Withdrawing your consent:

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at info@nabu.org.

Data Transfer:

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK data protection authorities to have an adequate level of data protection. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at info@nabu.org.

Use of your personal data for marketing purposes:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your personal data for marketing purposes.

Data Subject Rights:

If you are situated in the EEA, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise your rights under the GDPR, please contact us at info@nabu.org. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

TRANSMISSION OF INFORMATION TO OTHER COUNTRIES:

We are located in the United States. If you submit personal information to us, your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence, including, but not necessarily limited to, the United States.

PRIVACY POLICY UPDATES:

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time by posting the modified policy on this page, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website and App for the latest information on our privacy practices. Your continued use of the Services following the posting of any changes to this Privacy Policy means you accept such changes.

CONTACT:

For questions or concerns relating to this Privacy Policy or your information, we can be contacted at info@nabu.org or at the following address: NABU, NeueHouse 110 E. 25th St, New York, NY 10010.