The Crayon Initiative is strongly committed to protecting the privacy of its user community.
We collect two types of information: (1) non-personally identifiable information (Non-PII) for everyone who visits our Website; and (2) personally identifiable information (PII) for newsletter subscribers and everyone who requests products, services, information or resources. PII generally includes but is not necessarily limited to name, address, email address, phone and fax numbers, birthday, physical descriptors such as hair or eye color and height.
Non-PII. Website Usage Information. Cookies, IP Addresses and Logs. We employ “cookies” to collect information about you and your usage of the Website. A cookie is a small text file that is placed on your computer and collects information about how you use our Website. We also gather information about your individual use of our services, such as types of data accessed, times and volume of use, duration of sessions and other similar usage or system data. If you are not logged into our Website but are browsing the Website’s public areas, we log IP addresses and domain names. We cannot use this technical Non-PII to identify you personally.
Non-PII is aggregated for system administration and to monitor usage of the Website. It is utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content.
PII. For all newsletter subscribers and everyone who requests products, services, information or resources, PII includes information provided to The Crayon Initiative by you, including your contact information (such as name, address, zip code, email address, telephone number, fax number).
We use PII to provide information you request, or contact you when requested. We may use PII about you as a user, or former user, of the Website to develop and inform you about products, services, information or resources that we believe may be of benefit or interest to you or to help provide you with better information.
How Do We Share Your Information?
Disclosure of Your PII to Third-Parties. Except as provided below, we do not share your PII with non-affiliated third parties without your permission.
We may disclose your PII in connection with the sale, assignment, or other transfer of the website or a portion of the website, or as part of a corporate merger, consolidation, restructuring, sale of assets or other corporate change that affects us.
We may need to release your PII when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a criminal investigation, a court order, or legal process served on our Website. We may also share your personal information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms and Conditions of Use, or as otherwise required by law.
Service Providers: We also may disclose information to outside companies that help us bring you the products, services, information and resources we offer. For example, we may work with an outside company to: (a) manage a database of user information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide us storage and analysis; (e) provide fraud prevention; and (f) other services designed to assist us in maximizing our business potential. We require that these outside companies agree to keep confidential all information we share with them and to use the information only to perform their obligations in the agreements.
How Do I Opt-Out? If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and The Crayon Initiative will promptly remove you from all correspondence.
How can you update or correct your Personally Identifiable Information?
We believe you should have the ability to access and edit the Personally Identifiable Information that you have provided to us. You may change any of your Personally Identifiable Information in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this site. You may also access and correct your personal information and privacy preferences by writing us at:
The Crayon Initiative
540 Glasgow Circle
Danville, CA 94526
Please include your name, address, and/or e-mail address when you contact us.
We encourage you to promptly update your Personally Identifiable Information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information because of backups.
How Is My Information Protected? We take reasonable steps to protect the confidentiality of your PII, including physical, electronic, and procedural safeguards as required by law. We continually review our security procedures and mechanisms to ensure that reasonable protections are in place. Our website is scanned on a regular basis for security vulnerabilities in order to make your visit to our site as safe as possible.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
You can change your personal information by emailing The Crayon Initiative from the “Contact Us” page on this website.
Links To Other Sites. The Website may contain links to third-party sites that are not under our control. We are not responsible for the privacy practices, security or content of such third-party sites or your use of the same.
What else should you know about your privacy online?
You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 18 years of age.
You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in a discussion forums or other public areas on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you are online.
EU Privacy Notice
If you are a resident of the European Union (EU) or European Economic Area (EEA) whose personal information we collect, the following additional information applies to you.
1.1 – Where you are an EU or EEA resident and The Crayon Initiative knowingly collects your personal information (also called ‘personal data’), we will do so in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (‘GDPR’) and EU member state national laws that implement or regulate the collection, processing and privacy of your personal data (together, ‘EU Data Protection Law’).
1.3 – This Privacy Notice also provides information on your legal rights under EU Data Protection Law and how you can exercise them.
2 How personal data is collected
2.1 – The Crayon Initiative may hold and process personal data that is collected from organizations around the world, including within the EU/EEA.
2.2 – This is to make sure that the personal data that The Crayon Initiative receives and processes (so far as it relates to residents of the EU/EEA) is properly safeguarded in accordance with similar legal standards of privacy you would enjoy under EU Data Protection Law.
3 Direct Marketing
3.1 – If The Crayon Initiative provides direct marketing communications to individuals in the EU/EEA regarding services and/or events which may be of interest, this will be done in accordance with EU Data Protection Law, and in particular where we contact individuals for direct marketing purposes by SMS, email, fax, social media and/or any other electronic communication channels, this will only be with the individual’s consent or in relation to similar services to services that the individual has purchased (or made direct enquiries about purchasing) from The Crayon Initiative before.
3.2 – Individuals are also free to object or withdraw consent to receive direct marketing from us at any time, by contacting us using the email address below.
4 The lawful grounds on which we might collect and process personal data
4.1 – If we process your personal data for the above purposes, we will rely on one or more of the following lawful grounds under EU Data Protection Law:
(a) where you have freely provided your specific, informed and unambiguous consent for The Crayon Initiative to process your personal data for particular purposes:
(b) where we agree to provide services to you, in order to set up and perform our contractual obligations to you and/or enforce our rights:
(c) where we need to process and use your personal data in connection with our legitimate interests as a global network and being able to effectively manage and operate our organization in a consistent manner across all territories. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your legal rights and freedoms and, in particular, your right to privacy: and/or
(d) where we need to comply with a legal obligation or for the purpose of us being able to establish, exercise or defend legal claims.
4.2 – Please also note that some of the personal data we receive and that we process may include what is known as ‘sensitive’ or ‘special category’ personal data about you, for example, information regarding your ethnic origin or political, philosophical and religious beliefs. This is not the type of data that The Crayon Initiative would routinely collect, but if we process such sensitive or special category data we will only do this in specific situations where:
(a) you have provided this with your explicit consent for us to use it: or,
(b) there is a legal obligation on us to process such data in accordance with EU Data Protection Law
(c) it is needed to protect your vital interests (or those of someone else) such as in a medical emergency: or,
(d) where you have clearly chosen to publicize such information: or,
(e) where needed in connection with a legal claim that we have or may be subject to.
5 Disclosing your personal data to third parties
5.1 – We may disclose your personal data to certain third party organizations who are processing data solely in accordance with our instructions (called ‘data processors’) such as companies and/or organizations that support our operations (for example providers of web or database hosting, IT support, payment providers, event organizers, agencies we use to conduct fraud checks or mail management service providers) as well as professionals we use such as lawyers, insurers, auditors or accountants. We only use those data processors who can guarantee to us that adequate safeguards are put in place by them to protect the personal data they process on our behalf.
5.2 – We may also disclose your personal data to third parties who make their own determination as to how they process your personal data and for what purpose(s) (called “data controllers”). The external third party data controllers identified above may handle your personal data in accordance with their own chosen procedures and you should check the relevant privacy policies of these companies or organizations to understand how they may use your personal data.
5.3 – Other than as described above, we will treat your personal data as private and will not routinely disclose it to third parties without you knowing about it. The exceptions are in relation to legal proceedings or where we are legally required to do so and cannot tell you (such as a criminal investigation). We always aim to ensure that your personal data is only used by third parties we deal with for lawful purposes and who observe the principles of EU Data Protection Law.
6 How long we retain your personal data
6.1 – The Crayon Initiative retains personal data identifying you for as long as necessary in the circumstances.
6.2 – The Crayon Initiative has adopted a data retention policy for EU residents (which we may make available on request) that sets out the different periods we may retain personal data for in respect of relevant purposes in accordance with our duties under EU Data Protection Law. The criteria we use for determining the relevant retention and disposal periods we adopt are based on the purpose for which we hold data and the reasonable expectations of those whose personal data we collect in these circumstances, taking into account various legislative requirements and guidance issued by relevant EU regulatory authorities.
6.3 – In accordance with the above retention policy, the personal data that we no longer need will be disposed of and/or anonymized so you can no longer be identified from it.
7 Your personal data rights
7.1 – In accordance with your legal rights under EU Data Protection Law, you have a ‘subject access request’ right under which can request information about the personal data that we hold about you, what we use that personal data for and who it may be disclosed to as well as certain other information.
7.2 – Usually we will have one month to respond to a subject access request. However, we reserve the right to verify your identity and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests. We may also require further information to locate the specific information you seek and certain legal exemptions under EU Data Protection Law may apply when responding to your subject access request.
7.3 – Under EU Data Protection Law. EU/EEA residents also have the following rights. which are exercisable by making a request to us in writing:
(a) that we correct personal data that we hold about you which is inaccurate or incomplete:
(b) that we erase your personal data without undue delay if we no longer need to hold or process it:
(c) to object to any automated processing (if applicable) that we carry out in relation to your personal data. for example if we conduct any automated credit scoring:
(d) to object to our use of your personal data for direct marketing:
(e) to object and/or to restrict the use of your personal data for purpose other than those set out above unless we have a compelling legitimate reason: or
(f) that we transfer personal data to another party where the personal data has been collected with your consent or is being used to perform contract with you and is being processed by automated means.
7.4 – So we can fully comply, please note that these requests may also be forwarded on to third party data processors who are involved in the processing of your personal data on our behalf.
7.5 – If you would like to exercise any of the rights set out above, please contact us at the address below.
7.6 – If you make a request and are not satisfied with our response, or believe that we are illegally processing your personal data, you have the right to complain to the Office of the Information Commissioner in the United Kingdom.
The Crayon Initiative
540 Glasgow Circle
Danville, CA 94526