A. About us:
We are Change Incorporated. We are owned and operated by Vice Media. We are funded by global businesses to support editorially independent content. Through our journalism and content, we will set out to address problems and bring about long-term, impactful change.
C. Our values: We value your privacy and want to be accountable, fair and transparent with you about the way we collect and use your personal information. We aim to ensure that our collection and use of personal information is appropriate for the services and site that we provide to you and in accordance with all applicable data protection laws.
D. What rights you have: You have various rights in respect of your personal information. These are detailed in section 12 below. The rights include asking us to: (1) stop sending emails to you; and (2) consider any objections you may have in relation to how we use your personal information on the basis of our, or another person’s, legitimate interests.
1. About us
Project Change LLC is the controller of your data (ICO registration number ZA535624). Project Change LLC's principal place of business is at 49 S 2nd Street, Brooklyn, NY 11211, USA. Project Change LLC's UK office for contact on these matters is at Vice, 110-122 New North Place, London EC2A 4JA.
What does this Policy cover?
Here at Project Change LLC we take your personal data seriously. This policy:
sets out the types of personal data that we collect about you;
explains how and why we collect and use your personal data;
explains how long we keep your personal data for;
explains why we share your personal data, who we share it with and when;
explain whether any third parties collect your personal data on VICE Sites and for what purpose;
sets out the legal basis we have for using your personal data;
explains the effect of refusing to provide the personal data we request from you;
explains the different rights and choices you have when it comes to your personal data; and
explains how we may contact you and how you can contact us.
2. What personal data do we collect about you?
We collect the information necessary to be able to provide the services you request from us including but not limited to, the following:
subscribing to our newsletter;
submitting content privately on our Site;
participating in polls and quizzes on our Site;
participating in forums on our Site;
if available, taking part in competitions, promotions and surveys on our Site;
contacting us with queries, comments or suggestions; and
any other services or features that may be available on the Site from time to time, together, the “Services”.
We will collect different types of information from you (depending on the Services you request from us) in order to be able to provide you with the Services.
Information you share with us
When you subscribe to our newsletter, your email address.
When you submit content privately to our Site or contact us, your name and email address.
When you participate on forums on our Site, your username, email address and password for your account.
When you take part in a competition, promotion and/or survey, the information that you submit in your entry (which usually will include your name and email address). If you win a competition, we may collect your home address to deliver your prize.
When you participate in any polls and quizzes on our Site, your submissions are or will be made anonymous.
Interaction with the Site
We may also collect certain site usage information from you either directly or via a third party, whenever you visit or interact with us or our content found elsewhere on the internet (“Usage Information”). Such Usage Information includes IP address, your browser type, operating system, the types of the areas within our Site that you visit, including content that you browse and the time of day and your online identifier (i.e. the ID assigned to your device), among other information.
3. Where do we collect personal data about you from?
We may collect and access personal data about you from the following different sources:
Directly from you. This is information you provide while using our Site and Services;
Through social media widgets and similar links. Our Site contains links, ‘widgets’, ‘tweet’ and ‘like’ buttons linked to social media sites such as Facebook, Twitter, Instagram, tumblr and youtube.
4. How and why we use your personal data?
We use your personal data primarily to provide you with the Services you sign up for. For example if you sign up for our newsletters we will use your personal data to provide you with that newsletter. We may also use your data in the following ways:
to provide you with related services for example replying to your questions, complaints or comments;
to allow you to take part in competitions or promotions on our Site if you choose to take part in them and to deliver prizes if you win any competitions or participate in any promotions;
to verify that your details are correct when you register for our Services (including that your email address is active and valid);
to tailor content and offers and advertisements that we may display to you on third party social media platforms in relation to our Site;
to contact you in relation to your use of the Site and any changes we are making to our policies and terms and conditions;
to improve our Site and Services including processing your data to create anonymised and aggregated data that we use internally and share with third parties for analytical purposes; and
to track the effectiveness of our Site content.
5. What legal basis do we have for using your information?
Where we process your personal data, in addition to telling you what personal data we are processing, we are also obligated to tell you about the lawful basis we are relying on to process your personal data. The following sets out each lawful basis we rely on to process your personal data and the instances in which we rely on this basis to process such data.
Consent – We only collect and process personal data provided by you for marketing purposes where you have given your consent to receive our notifications, deals, special offers, and other information via email, SMS and social media for example. If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
6. How long do we keep your personal data for?
Newsletters – Until you unsubscribe or ask for your email address to be deleted;
Online Competitions and Promotions – For the duration of the specific competition/prize draw (including delivery of the relevant goods/prizes to you) and any subsequent involvement by you;
Event Guest Lists – For the duration of the applicable event and to invite you to similar events run by us for a period of 1 year after the event;
Online Usage Information – All Usage Information (defined above) is stored for a period of five years after your last interaction with the Site. This will be used for internal reporting and research purposes only; and
Digital, Film and Television Content - For as long as we are legally able to distribute the applicable piece of content and for archiving purposes.
You should inform us of any changes to your personal data so that we can keep it up to date.
If you wish to find out further information on how long we retain your personal data for you can contact us using the details in ‘How can you contact us?’ below.
7. Who do we share your personal data with?
1) Vice Media companies: We share your information with other VICE companies in the VICE Media group.
2) Service Providers: We also share your personal data with third parties engaged to provide the Services on our behalf.
3) Others in addition: we may disclose your personal data if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection and any replacement operators of all or part of our businesses.
We do not share your personal information with our funders.
To find out more about how we safeguard your information as related to transfers contact us on EUPrivacy@vice.com
8. Who else may collect personal data from you on the Site?
We use analytics providers to provide us with information regarding the use of the VICE Sites and the effectiveness of the advertisements that we place elsewhere on the Internet for example, in third party applications or elsewhere.
These service providers may set and access their own tracking technologies on your computer or mobile device (including cookies and web beacons) and they may otherwise collect or have access to information about your visits to and activity on the Site, as well as other web sites or online services. Some of these third parties may collect personal information from you over time when you visit the Site or other websites and services.
Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors with third party advertising companies, analytics providers and other vendors for the same purposes.
Our Cookies Policy can be found here.
9. What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary to provide the Services we will not be able to carry out those Services for you. If you withdraw your consent for us processing of your personal data, for example you withdraw your consent to receiving marketing from us, we will no longer process your data in this way and you will no longer receive marketing from us.
10. Do we use technology to build profiles about you?
We may use signals on your browser which analyse the types of content you have consumed. We can then provide you with relevant Changed Incorporated content recommendations and other types of content that you might enjoy watching on the Site. Types of input signals can include engagement, time spent on site, and social media interests.
You have a right to object to this activity, please see below for information on this right and how to contact us if you have any questions.
12. What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
3) The right to rectification – You’re entitled to have your information corrected if it’s inaccurate or incomplete. For more information or to request correction, please click here.
4) The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. For more information or to request erasure, please click here.
5) The right to restrict processing – You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. For more information or to request restriction, please click here.
6) The right to data portability – You have rights to obtain and reuse your personal data for your own purposes across different services. This enables you to move, copy or transfer your information easily between our IT systems and third parties safely and securely, without affecting its usability. For more information or to request data portability, please click here.
7) The right to object – You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent). For more information or to object, please click here.
8) The right to lodge a complaint – You have the right to lodge a complaint with your national data protection regulator about the way we handle or process your personal data. In the UK, the data protection regulator is the Information Commissioner's Office (ico.org.uk).
9) The right to withdraw consent – If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
baseless or excessive/repeated requests, or
further copies of the same information.
Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example, if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
13. How will we contact you?
We may contact you by email or if you contact us via our social media platforms, we will respond directly. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us at EUPrivacy@vice.com.