Last Updated: February 19, 2018
1. Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including:
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address
- Credit and debit card number
- Social media profile picture, friends or connections, age, gender, location, social networking ID, and other information shared with us by social networks and social media platforms that you choose to connect with the Service
Collection of Personal Information
We and our service providers may collect Personal Information in a variety of ways, including:
- Through the Service: We may collect Personal Information through the Service, e.g., when you submit a tip or leak information to us (“Tips”), sign up for our email list, or make a donation to us.
- Offline: We may collect Personal Information from you offline, such as when you contact us through the phone or traditional mail.
- From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. In addition, if you elect to connect your social media account to the Service, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
Use of Personal Information
We and our service providers may use Personal Information for the following purposes:
- To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies, as well as marketing communications that we believe may be of interest.
- To personalize your experience on the Service by presenting opportunities or content tailored to you, and to facilitate social sharing functionality.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and services, enhancing, improving or modifying the Service, identifying usage trends, determining the effectiveness of our promotional campaigns, fundraising campaigns, and operating and expanding our organizational activities.
Disclosure of Personal Information
Your Personal Information may be disclosed:
- To our third party members or partners for journalistic purposes when you send us Tips.
- To our third party service providers, who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- By you, in comments, posts, or other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. Notwithstanding the previous sentence, ICIJ respects the anonymity of sources. If you submit Tips to us, we will make reasonable efforts to protect your identity as the submitter (consistent with journalistic standards).
In addition, we may use, disclose, or transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our activities, assets, or stock (including in connection with any bankruptcy or similar proceedings).
2. Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner that no longer reveals your specific identity
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Service functions properly.
- Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Service, pages visited, language preferences, and other anonymous traffic data. We and our service providers use such information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about your use of the Service in order to continually improve its design and functionality, understand how it is used, and assist us with resolving questions regarding it. We do not currently respond to browser do-not-track signals.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Service (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Service and response rates.
- IP Address: Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Service, along with the time of the visit and the pages that were visited. Collecting IP addresses is standard practice and is done automatically by many websites and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Service. We may also derive your approximate location from your IP address.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
3. Third-Party Services
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Social Media Pages.
4. Our Advertising
We may use third-party social media platforms to serve advertisements that may be of interest to you when you use such platforms. If you prefer not to receive such advertisements, please adjust any applicable preferences that the social media platform makes available to you.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
6. Choices and Access
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving marketing emails from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out using the ‘Unsubscribe’ link at the bottom of email communications from ICIJ, or by emailing your request to email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or suppress your Personal Information
If you would like to review, correct, update, suppress, restrict, or delete Personal Information that you have provided to us, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at firstname.lastname@example.org, or by mail to:
The Online Editor
The International Consortium of Investigative Journalists
1710 Rhode Island Ave NW,
Washington, D.C. 20036
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a donation, you may not be able to change or delete the Personal Information provided until after the completion of such donation). There may also be residual information that will remain within our databases and other records, which will not be removed.
7. Retention Period
8. Use of the Service by Minors
The Service is not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
9. Jurisdiction and Cross-Border Transfer
The Service is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Service you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
10. Sensitive Information
we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Service or otherwise to us.
12. Contacting Us
The Online Editor
The International Consortium of Investigative Journalists
910 17th Street NW, Suite 410
Washington, D.C. 20006
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.