SCOPE OF THIS POLICY
Privacy is important to us, and we are strongly committed to being transparent and fair in our processing of personal data. This Privacy Policy describes how we – Animal Kingdom, (together with its affiliated websites – “AK”, “we”, “our” or “us”) collect, store, use, and disclose personal data regarding individuals (“you”) who:
- visit or otherwise interact with our website (“Visitors”), available at animalkingdom.org or any othe website, webpage, email, text message or online ad under our control (collectively – the “Site”)
- are our prospective or existing partners (“Partners”); or
- use our social engagement and content personalization platform, or any of our related services (collectively with the Site – the “Services”), at any of our partners’s websites and digital properties (“Users” and “Partner Sites”, respectively
If you are our Visitor or Partner, please read this Privacy Policy carefully and make sure that you fully understand and agree to it. You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services. If you are a User of one of our Partner Sites, you also choose not to provide us with “optional” Personal Data, or to request to delete or opt-out of certain processing activities (see Section 8), but please keep in mind that limiting our processing may also result in us not being able to provide you with the full range of our services or with the best user experience when using our Services.
Data Collection
We collect data regarding our Visitors, Users and Partners. Such data is typically collected and generated through the Visitor’s or User’s interaction with our Services, through automatic means, directly from such Visitor or User, from our Partners, or from other third parties.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):
- Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Visitors and Users in connection with our Services.
- Data received from you: You may provide us with Personal Data such as your name, contact details (such as e-mail, phone and address), account login details (such as username and hashed passwords), workplace and position, profile picture, interests, preferences, and free-form description (collectively, “Account Data“), as well as any other data you choose to provide when you use our Services, create a user account, publish content and interact with others via our platform, or contact us.Partners may provide us additional Account Data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.In the event that a User registers to the Services through their existing third-party Social Network Account (namely the User’s Facebook, Twitter, Microsoft or Google+ account, or other approved social platforms or networks), or through a “Single Sign-On” (SSO) mechanism implemented by any Partner Site, then such third-party social network or Partner Site may provide us with certain information about such User, as is stored in and/or made available by the User through their Social Network or Partner Site Account. This includes the User’s name, public profile picture, URL address, Social Network Account User ID, e-mail address, date of birth, gender, occupation or work information, education and other information which the User made public. This Personal Data is automatically provided to and stored by OpenWeb when registration to the Services is conducted via the User’s Social Network or Partner Site Account.
- Data received from our Partners and Users: our Partners and Users may provide us with data concerning their friends, community members, colleagues or employees, so we could contact them regarding our Services (e.g. to offer or provide them with our Services). Such data usually refers to such individuals’ name, role, company and work or personal contact details, as relevant, however additional data may be provided at the Partner’s discretion.
- Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn
Data Uses
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, advertising, customer service and support operations, and protecting and securing our Visitors, Users, Partners, ourselves and our Services, as well as members of the general public.
If you reside or are using the Services (i) in a territory governed by privacy laws which determine that “consent” is the only legal basis for the processing of Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Services) or (ii) in the EEA and provide us with Personal Data, the processing of which requires “consent” under applicable law (e.g. ‘special categories’ under the GDPR, or use of cookies under the e-Privacy directive and related local legislation), your acceptance of our Terms of Service and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us at support@animalkingdom.org or follow the instructions in Sections 6 or 8 below (as the case may be).
Specifically, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To manage and deliver personalized advertisements and content more effectively, including contextual, interests-based and other types of targeted advertising based on the User’s activity on our Services and Partner Sites, their preferences or other data available to us or to our business partners, including for re-targeting purposes;
- To authenticate the identity of our Users, and to allow them access to our Services;
- To provide our Visitors, Users and Partners with assistance and support;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To contact our Visitors, Users and Partners with general or personalized service-related messages and calls, and promotional messages and calls (as further described in Section 6 below); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security and content compliance measures, including for the purposes of preventing and mitigating the risks of fraud, abuse, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
Data Retention and Location
- Data Location: We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States, the European Union, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law. Animal Kingdom (DRI Travel) is headquartered in Dallas County, Texas, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. While privacy laws may vary between jurisdictions, AK and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
- Data Retention: We typically retain Users’ Personal Data for as long as their account is active, or as long as we consider necessary for the purposes described herein (which may extend even after their account is inactivated). We keep Visitors’, Users’ and Partners’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services. We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our internal data retention policy. Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at support@animalkiingdom.org.
Data Sharing
- Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, e-mail distribution and monitoring services, text messaging services, session recording, content moderation, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
- Sharing Personal Data with our Partners: We may share the Personal Data of Users who use our Services on a Partner Site, with the Partner operating such site (including data and communications concerning their user account), regardless of their account registration method. We may also share limited Personal Data of Users with our Partners for ad and content personalization purposes (see Section 5 below). Please note that AK is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of such Partner, that itself acts as the “Data Controller” of such data (as further described in Section 10 below).
- Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of AK, any of our Visitors, Users or Partners, or any members of the general public.
- AK Subsidiaries and Affiliated Websites: We may share Personal Data internally within our group for the purposes described in this Privacy Policy. In addition, AK or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, AK may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
Communications
- Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us, e.g. phone, mobile, web notifications or e-mail) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
- Notifications and Promotional Communications: We may send you notifications, messages and other updates about new features, offerings, events and special opportunities or any other information we think our Users or Partners will find valuable. We may provide such notices through any of the contact means available to us, through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify the AK at any time by changing your communications preferences in your account, by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive, or by sending an email to support@animalkingdom.org.
Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your Personal Data held with AK, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or to opt-out of the sale of your personal information, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by email at support@animalkingdom.org.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
OpenWeb adheres to the Self-Regulatory Principles set forth by the European Interactive Digital Advertising Alliance (EDAA), and to the Interactive Advertising Bureau’s (IAB) Europe Online Behavioral Advertising Framework.
Children's Policy
Our Educational Services may attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will remove any connected data use and promptly delete any Personal Data stored with us with regard to such child. The AK will seek to secure parental data for the purpose of administering any services on the AK site as desired by the family. If you believe that we might have any such child related data, please contact us by email at support@animalkingdom.org.
Data Controller/Processor
Certain data protection laws and regulations, such as the EU GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
AK is typically the “Data Controller” of its Visitors’, its Users’ and its Partners’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. Under the CCPA, we are either the “business” with respect to Users’ Personal Data (if the User are directly engaged with us), or a “third party” (if such Users do not directly engage with us, whilst we process their personal information on our own behalf).
In the relationship between a publishing Partner and AK, such Partner shall act as “Data Controller” (or “business” under the CCPA) with respect to its own end-users and Users of their Partner Site(s). In certain instances, The AK will only be deemed as the Data Processor (or service provider) regarding such end-users’ Personal Data, if we process such end-users’ data on behalf of our Partner and in accordance with its reasonable instructions, subject to our Terms of Use and other commercial agreements.
If you would like to make any requests or queries regarding Personal Data we process on our Partner’s behalf, please contact such Partner directly. For example, if you are an end-user of our Partner who wishes to access, correct, or delete data processed by AK on behalf of such a Partner, please direct your request to the relevant Partner.
Additional Notices
- Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
- External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.
Please be advised that when you post links to/from YouTube, we make use of the YouTube API in order to support the preview of such content. Such activity is governed by YouTube TOS and Google Privacy Policy. We encourage you to review their practices carefully.
Questions, Concerns or Complaints: If you have any additional comments or questions about this Privacy Policy or if you have any concerns regarding your Personal Data, please contact us by email at support@animalkingdom.org.