Updated: October 13, 2021

Privacy Statement 

 

The Climate Boot Camp (the “Event”) is produced by the Harvard Alumni for the Climate and Environment Corp., a Massachusetts non-profit corporation, with a business address of 67 Oak Street, Unit 2, Somerville, MA  02143, USA (“HACE”), and The Alliance for Climate Protection d/b/a The Climate Reality Project, a Washington, D.C. nonprofit corporation with a business address of 555 11th Street, NW, Suite 601, Washington, DC 20004, USA (“Climate Reality”) (collectively, “we”, “us”, and “our”). The digital event web platform and eWorkbook digital infrastructure (collectively the “Platform”) functionality is kindly licensed to us from Glinter LLC, a Delaware limited liability corporation (“Glinter”).

 

This privacy statement is intended to inform participants of the Climate Boot Camp what information we collect, how this information is used and what steps we take to protect this information, as well as providing participants a process to update, change or delete their personal data.

What Personal Data Is Used For The Climate Boot Camp?

 

Personal data is any information from or about an identified or identifiable person, including information that we can associate with an individual person. We may collect and process the following categories of personal data when participants attend, or interact with, the Climate Boot Camp: 

  • Registration Information: Information people provide when registering for the Climate Boot Camp, including name, contact information, responses to registration questions, and other registration information provided by people or requested by the host.

  • Participant Information: Information provided by participants which may include name, display name, picture, email address, phone number, stated locale, or other information provided by the participant.

  • Settings: Information associated with the preferences and settings on the participant profile, which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.

  • Device Information: Information about the computers, phones, and other devices participants use when interacting with the Climate Boot Camp, which may include information about the device speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals). 

  • Climate Boot Camp Content: Content generated during the Climate Boot Camp or hosted on the Platform which may include audio, video, in-meeting messages, chat messaging content, transcriptions, written feedback, responses to polls and Q&A, and files, as well as related context, such as invitation details, meeting or chat name, or meeting agenda. Content may contain a participant’s voice and image, depending on the participant’s settings, what they choose to share, their settings, and what they do on the Climate Boot Camp. 

  • Product and Website Usage: Information about how participants and their devices interact with the Climate Boot Camp Platform, such as: when participants join and leave a meeting; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other participant inputs that help us to understand feature usage and improve product and event design; and other usage information and metrics. 

  • Communications with Us: Information about a participant’s communications with us, including relating to support questions, their registration, transactional information, and other inquiries.

 

Why Does the Climate Boot Camp Use Personal Data?

 

We use personal data to conduct the following activities:

 

  • Provide the Climate Boot Camp experience: To provide the Climate Boot Camp’s features and services to its participants. This may also include using personal data for participant support, which may include accessing registration, participant, setting, and device information. 

  • Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, and secure the Climate Boot Camp Platform. 

  • Communicate with Participants: We use personal data (including contact information) to communicate with participants about registration and attendance, and changes to our policies and terms. We also use participant information to respond to when contacted. If a participant opted-in to mass email communications from HACE and Climate Reality, we will use the participant’s information to send those subscribed emails. 

  • Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies. 


 

How Do We Share Personal Data?

 

We provide personal data to third parties only as described below:

  • Vendors: HACE and Climate Reality work with Glinter and its vendors to provide and support the Climate Boot Camp Platform and enable participant interaction with the Platform. In addition, HACE and Climate Reality use Zoom Video Communications, Inc. (“Zoom”) as a vendor to provide access for breakout functionality between Climate Boot Camp sessions, and attendee data is used to create attendee log-ins. Attendee use of Zoom is subject to accepting Zoom’s Terms of Service and Privacy Policy. Glinter and its vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services for the Climate Boot Camp or as required by law. Vendors may not retain participant data after the duration contractual permissions allow except for legal reasons.

  • For Legal Reasons: We may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; 4) protect participants’ rights and property; and (5) resolve disputes and enforce agreements. 


 

Who Can See and Share Participants’ Personal Data While Using the Climate Boot Camp?

 

When participants send messages, attend meetings, and interact with the Climate Boot Camp, other people and organizations, including third parties outside the meeting, webinar, or message, may be able to see content and information that they share: 
 

  • HACE and Climate Reality, the hosts of the Climate Boot Camp: HACE and Climate Reality host the Climate Boot Camp and participants’ personal data may be reviewed to support participant interaction and progress through the program as detailed above.

  • Glinter, the host of the Platform: Glinter hosts the Platform that the Climate Boot Camp uses, but only for a temporary duration and during that time participants’ personal data is used to facilitate participant progress through the Platform. Glinter may work with vendors to provide Platform and Event functionality, such as without limitation, the chat feature, and Glinter’s vendors may have access to participants’ data although those vendors are not permitted to retain or process participants’ data.

  • Zoom, the host of the Climate Boot Camp breakout sessions, will have access to attendee information that is provided to create attendee log-ins for the sessions. Zoom’s collection and use of attendee data is described in its privacy policy found here: https://explore.zoom.us/docs/en-us/privacy.html

  • Meeting Hosts and Other Participants:  Meeting hosts and other participants in a meeting or message board may be able to see participants’ email, display name, and profile picture.  Meeting hosts and participants can also see and record or save meeting content, audio transcripts, messages visible to them, and files or other information shared during a meeting.  Hosts may also be able to see responses to Q&A and polls generated during the meeting.

  • Webinar Panelists and Attendees:  Only panelists might be visible to attendees during a session, but participants who agree to unmute can be heard by other attendees.  If an attendee agrees to become a panelist during a webinar, they may be visible to other attendees, depending on settings.  Panelists and attendees may be able to see the name of a participant who asks a question during a Q&A, along with their question, unless the participant submits the question anonymously. 

 

How to Contact Us

 

To exercise your rights or if you have any privacy-related questions or comments related to this Privacy Statement, please contact us by writing to our addresses listed at the top of this policy, or by emailing us at contracts@climatereality.com

 

Retention

 

We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.

 

The criteria used to determine our retention periods include the following:

  • The length of time participants use the Climate Boot Camp Platform;

  • Whether we decide to stop making the Climate Boot Camp available to the participants;

  • Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of participant transactions for a certain period of time before we can delete them); or

  • Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

 

Privacy Rights and Choices

 

Participants Data Rights 

 

A participant’s rights in relation to their personal data processed by us as a controller specifically include: 

  • Right of access and/or portability: Participants have the right to access any personal data that we hold about them and, in some circumstances, have that data provided to them so that they can provide or “port” that data to another provider;

  • Right of erasure: In certain circumstances, participants have the right to the erasure of personal data that we hold about them;

  • Right to object to processing: In certain circumstances, participants have the right to request that we stop processing their personal data and/or stop sending them marketing communications;

  • Right to rectification: Participants have the right to require us to correct any inaccurate or incomplete personal data;

  • Right to restrict processing: Participants have the right to request that we restrict processing of their personal data in certain circumstances.

 

In order to exercise any of the rights as to personal data controlled by us, or for any other questions about our use of participants’ personal data, please send a request to our contact information, above. Please note that we may ask the requestor to provide us with additional information in order to confirm their identity and ensure that they are entitled to access the relevant personal data. Participants also have the right to lodge a complaint to a data protection authority. For more information, participants should contact the local data protection authority for their country.

 

Legal Basis for Processing Personal Data 

We only use participant information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when we process personal data as a controller for individuals in countries other than the United States, we rely on the following legal bases as applicable in their jurisdiction:

  • As necessary for our contract: When we enter into a contract directly with a participant, we process their personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing access to the Climate Boot Camp and its features and events, and manage our relationship and contract, including compliance with contractual obligations and related administration). If we do not process the participant’s personal data for these purposes, we may not be able to provide them with all the functionalities of the Climate Boot Camp;

  • Consistent with specific revocable consents: We rely on participants’ prior consent in order to utilize cookies to engage analytics partners to deliver analysis of our Platform usage. Participants have the right to withdraw their consent at any time by contacting us at the email address above;

  • As necessary to comply with our legal obligations: We process participants’ personal data to comply with the legal obligations to which we are subject for the purposes of compliance with nations’ laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity and compliance with privacy laws;

  • As necessary for our (or others') legitimate interests, unless those interests are overridden by a participant’s interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the Products (which includes compliance with contractual obligations and related administration and support); (ii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iii) send marketing communications, advertising, and promotions to those participants who opted in to receive those communications; and (iv) meet our corporate and social responsibility commitments, protect our rights and property and the ones of the participants, resolve disputes, and enforce agreements.

 

International Data Transfers

The Climate Boot Camp was not marketed directly in or to any country outside of the United States. However, many recipients of invitations to the Climate Boot Camp do not reside in the United States, and so their data will be transferred, stored, and processed in the United States where we are based. 

 

Therefore, by using the Climate Boot Camp or providing personal data for any of the purposes stated above, participants acknowledge that their personal data may be transferred to and stored in the United States where we are established. 

 

Updates to This Privacy Statement

 

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data and will post the updated Privacy Statement on this website with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify participants and provide an opportunity to review before participants choose to continue using the Climate Boot Camp.