Last Updated: 6/11/20
Information We Collect
You may provide Personal Information directly to us in a number of ways. "Personal Information" is information that identifies you as an individual or relates to an identifiable individual. For example:
- When you register for or use our Services, we may ask you for Personal Information, such as your name, e-mail address, postal address, zip code, telephone number, payment card information, or in certain situations your social media account ID.
- When you make a donation or a purchase from our Services, we may ask you for payment information, such as your credit card number and expiration date.
- When you use our interactive online features (such as forums, blogs, or other services that allow you to post content), we receive whatever you post, which may include Personal Information.
- When you contact us for assistance with the Services, we receive any Personal Information you send us in that correspondence.
- When you respond to one of our surveys.
We may also receive your Personal Information from third parties and may combine this information with any information we have collected directly from you. For example, we may receive:
- Information from fundraising websites or applications regarding donations that you have made to us through these third-party websites or applications, including your birth date and other profile information.
- Information from providers of mailing lists.
Use of Personal Information
To the extent permitted by applicable law and any applicable contract to which we are a party (for example, with a school or school district), we use Personal Information for legitimate purposes that support and further our mission. These purposes include:
- To provide the Services and fulfill your requests.
- To provide you with the products, Services, and information you request.
- To respond to your inquiries and correspondence.
- To send administrative information to you, such as legal notices, changes to our terms, conditions, and policies, and other information that may be relevant to your use of the Services, such as account status, renewal, or any problems with your account.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- To send you our newsletter, advocacy or fundraising materials, and surveys.
- To send you our newsletter.
- To solicit a donation from you.
- To inform you about important public policy issues that relate to our mission or that might affect our Services and encourage you to contact your lawmaker.
- To coordinate volunteer efforts.
We will engage in this activity with your consent or where we have a legitimate interest.
- To allow you to participate in a promotion.
- To permit you to participate in a sweepstakes, contests, or other promotions, which may be subject to additional rules about how we may use your Personal Information.
We will engage in these activities with your consent or to manage our contractual relationship with you.
- To aggregate and/or anonymize Personal Information.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data, which we may use and disclose for any purpose, including for research and analysis.
- To support and further our mission.
- For data analysis, for example, to improve the efficiency of our Services.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements.
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
- For developing new products and services.
- For enhancing, improving, or modifying our current products and services.
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users.
- For determining the effectiveness of our fundraising and promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
- For operating and expanding our organizational activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users' interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Finally, certain Services use data collected from you in a manner specific to those Services. For a more complete description of the way data collected from you is used by individual Services, please select a Service from the list below:
Sharing of Personal Information
We are committed to maintaining your trust, and we want you to understand when and with whom we may share your Personal Information. To the extent permitted by applicable law and any applicable contract to which we are a party (for example, with a school or school district), your Personal Information will be disclosed:
- To our third-party service providers, to facilitate services they provide to us.
- These can include providers of services such as payment processing, information analysis, email delivery, auditing, and other services.
- By you, if you choose to use interactive features of the Services.
- You may choose to use message boards, chat, blogs, and other services to which you are able to post information and content. Any information you post or disclose through these services will become public.
- We may also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To protect our legal rights, privacy, safety, security, or property and/or that of you or others.
- To prevent fraud.
- For risk management purposes.
- To prevent copyright infringement.
- To comply with applicable law, which can include laws outside your country of residence.
- To comply with or respond to law enforcement or legal process or a request for cooperation by a government or other legal entity. If we intend to disclose a user's personal information to law enforcement or in response to a legal process, we will make reasonable efforts to promptly notify the user—and, if we know that the user is under 18, the user's parent or legal guardian—unless directed not to by a court of law. Please note that such legal obligations or requests may arise under laws outside of your country of residence.
- In connection with a transfer or proposed transfer of our assets or all or any part of our organization.
Finally, certain Services share information collected from you in a manner specific to those Services. For a more complete description of the way information collected from you is shared by Bookshare related Services, please click on the link below:
We may receive certain “Other Information” automatically when you use our Services. Other Information does not reveal your specific identity or directly relate to an identifiable individual.
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 computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Using pixel tags and 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 Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about use of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies.
- We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel . You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- 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 Services, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
Do Not Track
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Benetech does not take any specific action in response to these signals.
Protection of our users' Personal Information is important to us, so we seek to maintain security safeguards designed to protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of your Personal Information within our organization.
Please note, however, that no information transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your Personal Information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us at firstname.lastname@example.org.
Choices and Access
You may request to review, correct, update, suppress, restrict, or delete your Personal Information, object to the processing of Personal Information, or request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), by contacting us at email@example.com. We will respond to your request consistent with applicable law. 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 Personal Information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
If you are using the Services through your school or school district, please contact your school or school district to request to access or take other action with respect to your Personal Information.
If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or Personal Information that you have posted to the Services by writing to firstname.lastname@example.org. Please note that your request does not ensure complete or comprehensive removal of the content or Personal Information, as, for example, some of your content may have been reposted by another user.
The privacy and protection of children is of great importance to us. We do not knowingly collect, use, or disclose Personal Information from children under the age of 18 without obtaining consent from a parent or legal guardian, except as otherwise permitted by applicable law. For minor users who are signed up for Bookshare or other Services by their school, the school may provide Benetech with such students' Personal Information, and, to the extent that parental or guardian consent to our receipt and use of such information is required under any applicable law, the school is responsible for obtaining that consent.
We do not knowingly allow Bookshare members, or users of other Services, who are under the age of 18 to make Personal Information publicly available through our Services. If a member under the age of 18 (or his or her parent or legal guardian) wishes to review, modify, or delete the minor member's Personal Information and refuse to permit further collection or use, please contact us using the contact information below.
Third-Party Payment Service
We retain Personal Information for as long as needed or legally permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you; for example, for as long as you have an account with us or keep using the Services;
- Whether there is a legal obligation to which we are subject; for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; or
- Whether retention is advisable in light of our legal position; for example in regard to applicable statutes of limitations, litigation, or regulatory investigations.
Social Networking and Third‑Party Sites
Social Networking Services
You may use other third-party social media providers in conjunction with our services, including in certain instances to access our Services. For example, you can use third-party social networking services, including, but not limited to, Facebook, LinkedIn, Pinterest, Google, and Twitter, to share information about your experience on our Services with your friends and followers on those social networking services. The third-party social networking services may be able to collect information about you, including your activity on our Services. The third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies.
If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts. We are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, Twitter, or any other application developer, application provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.
Links to Third-Party Sites and Services
You may choose to receive promotional emails, newsletters, and similar communications from us. Even if you have opted in, you may opt out of receiving these communications by clicking on the opt-out or “unsubscribe” link included in the promotional emails. Please note that opt-out requests may take up to 10 business days to be effective. Your opt-out request will not apply to messages that are not promotional in nature. For example, we may contact you concerning your account or any purchases or donations you have made with us, even if you opt-out of receiving promotional email messages.
Jurisdiction and Cross-Border Transfer
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 Services, you understand that your information will be transferred 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.
ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en ) . For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses, to protect your Personal Information. You may obtain a copy of these measures by following this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en .
Additional Information Regarding the EEA
- Contact our Data Protection Officer (DPO) at email@example.com.
- If your issue or matter is not satisfied by contacting firstname.lastname@example.org, you may also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .
Bookshare® is a nonprofit online library dedicated to providing accessible books and other materials (“Content”) to people with print disabilities. We have also partnered with outside organizations and developers to provide our members with mobile e-reader applications, such as Read2Go and Go Read. These e-reader applications allow members to access e‑books from Bookshare on their mobile devices. In order to provide these services, Bookshare collects, uses, and shares certain Personal Information relating to its members' disability status, education, veteran status, and book-related information, as more fully described below. This Personal Information may be input by you directly, or may be input on your behalf by an Organizational Member such as a school, library, veterans' organization, or other organization that provides services to people with print disabilities.
Information Bookshare Collects
In order to comply with the laws that allow Bookshare to provide copyrighted material to people with print-related disabilities that prevent them from reading or handling print materials, Bookshare requires proof of a print-related disability, which may include medical information, for each member who wishes to receive copyrighted Content. Further, because Bookshare was built to serve members with print disabilities, Bookshare may collect other information that reflects the nature of its members' disabilities in order to better serve the member, as well as to comply with Department of Education requirements. For example, Bookshare may collect information that a certain member prefers to read books in Braille and was referred to Bookshare by a school for the blind.
If a member joins Bookshare through an organization, then the Organizational Member typically collects the member's proof of a print-related disability, not Bookshare. However, the Organizational Member may share the nature of the member's print-related disability with Bookshare and will be obligated to provide proof of the print-related disability to Bookshare on request, in order to confirm that the member is eligible to use Bookshare.
To streamline the process of verifying eligibility, Bookshare has agreements in place with other nonprofit organizations serving people with disabilities (“Verification Partners”), including National Library Service for the Blind and Physically Handicapped (“NLS”), Learning Ally (formerly RFB&D), Hadley School for the Blind and Visually Impaired, and various U.S. and international organizations. If a potential member has already provided proof of a print-related disability to one of our Verification Partners, the potential member may use this proof to sign up for Bookshare by filling out our online form. Upon receipt of this form, Bookshare will send the potential member's name, address, email, birth date, and/or other information on the submitted form to the Verification Partner, and the Verification Partner will provide confirmation that the member has a qualifying print-related disability and is thus eligible to use Bookshare.
Educational Information and Veteran Status
Bookshare partners with the U.S. Department of Education to provide free access to students in the United States. Bookshare also partners with other nonprofit and for-profit organizations to provide greater access to children with qualifying print-related disabilities. To further this goal, Bookshare collects information on members' education, including, but not limited to, a member's grade, birth date, school name, school address, school district, and whether the member is enrolled in a qualifying Individualized Education Plan (“IEP”) or a 504 Plan.
Bookshare also collects information on whether or not a member is a minor. For each member with an Individual Membership who is a minor, Bookshare may collect the contact information of the member's guardian, such as the guardian's name, e-mail address, postal address, zip code, and telephone number.
Finally, Bookshare collects information on whether the user is a U.S. Veteran. This information is only used to provide free or discounted services and special programs to qualifying Veterans and in aggregated, de-identified reporting.
Bookshare is dedicated to expanding access to books for members with qualifying print-related disabilities. To further this goal, as well as to comply with copyright law requirements, publisher agreements, and funder contracts, Bookshare maintains transaction logs of the materials downloaded by members. These transaction logs contain information such as the title and author, the member who downloaded the book, the date and time of the download, the format of the download, and the status of the download. Further, for each download of a copyrighted work, Bookshare embeds a digital fingerprint in the book download. Bookshare stores this digital fingerprint so that it can trace downloaded material back to the original downloader to determine the source of any unauthorized copies of Bookshare material.
If a member uses the Read Now option to launch a book using Bookshare Web Reader, Bookshare also records whether the book was opened by the member and remembers the last read location to keep the member's place in the book.
Bookshare also stores each reader's preferred download format and preferred language.
As part of its efforts to build and improve the Bookshare collection, Bookshare may accept uploads of Content, accessibility improvements (such as image descriptions), and reviews of books. Bookshare maintains transaction logs of these activities.
Information From Our International Partners
If a member lives outside of the United States, Bookshare may also receive information from an international Membership Partner. For our international members, the International Partner in the member's country of residence may collect the member's proof of print-related disability, rather than directly by Bookshare. In that case, the International Partner may share the nature of the member's print-related disability with Bookshare and will be obligated to provide proof of the disability to Bookshare upon request, in order to confirm eligibility to use Bookshare.
Use of Personal Information
- To provide the Bookshare service to a member, including:
- To verify that a potential member has a qualifying print-related disability;
- To remember a member's last place in a given piece of Content;
- In the case of minors, to limit access to Content coded as adult Content; and
- To provide information in the course of communications between our Services and compatible e-reading applications. If you choose to use an e-reading application to use Bookshare, that product will have access to certain information from your Bookshare account. Similarly, if you have an Organizational Membership, the persons responsible for your Organizational Member account may use an e-reading application to access your information. For example, e-reading applications can access your name, account settings, and history of downloading books. To provide product improvements such as suggested content based on a member's past reading patterns. We will engage in these activities either with your consent or because we have a legitimate interest.
- To manage our contractual relationship with you and/or to comply with a legal obligation.
- To protect our rights and those of others.
- In cases of suspected abuse where copyrighted Content has been (or is suspected to have been) made available to unqualified individuals, to trace copyrighted Content back to the user using the user‑identifiable information embedded in downloaded Content.
We will engage in this activity as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so.
- To track the quality of uploads and reviews by members, organizations, and volunteers. In particular, we may identify the uploading person with the Content on the website, and we may also publicize individuals who upload particularly high-quality Content or reviews.
Sharing of Personal Information
- Upon the member's request, if you have already had your qualifying print-related disability verified by a Verification Partners and would like us to use that information to qualify you for Bookshare, we will do that. Similarly, if a Verification Partner requests that we verify your print-related disability, we may confirm or deny that you have provided us with proof of disability.
- To confirm the accuracy of a member's information with our International Partners. We will only share Personal Information with our International Partners that the International Partner originally collected—the International Partner will not have direct access to individual members' Personal Information maintained by Bookshare.
- With the entity that has funded the member's use of Bookshare.
- To provide usage information about individuals' accounts to the person(s) responsible for the associated Organizational Member accounts. For example, we will provide detailed information on the contact information, reading history, and reading preferences of the organization's staff or members to that organization.
We may provide aggregate reports on Bookshare usage to government, nonprofit, and for‑profit partners, such as publishers and developers of e-readers and other assistive technology tools. These reports will not include any Personal Information, and may include, for example, aggregated information on the number of books downloaded by Bookshare users in a given time frame, and this information may be broken down by demographic information, such as location or school district. Further, these aggregate reports may be used by Bookshare or its partners to advertise their products, to compete for grants, or for any other purpose.
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