If you have any questions about this policy or how EarthDNA processes personal information, please contact our Privacy Officer as follows.
1. Personal Information
EarthDNA, Inc. is a nonprofit organization focused on climate action, sustainability, and circular economy solutions. EarthDNA maintains a company website and operates the S.H.O.E.S. (Sustainable Handheld Organized Ecosystem for Secondhand Footwear) mobile application. The S.H.O.E.S. mobile application helps users identify shoes, assess shoe condition, estimate value, determine what to do with shoes next, and participate in footwear circularity initiatives, including collection, sorting, donation, resale, recycling, and related pathways (collectively, the "Services").
In connection with providing the Services and conducting our operations, we collect and process the following categories of personal information, including personal information we have collected and processed in the preceding 12 months.
- Name and Contact Information, such as first and last name, email address, phone number, country, zip code, and other similar contact information.
- Image and Submission Information, such as photographs and images of your shoes submitted through EarthDNA's application, including pictures of shoes, labels, metadata, and other information associated with those submissions. We ask that you submit only images of your shoes. If an image you submit contains content other than the shoe or related item, EarthDNA may block the submission or use technical measures to remove, obscure, or minimize background content before processing the image.
- Donation and Supporter Information, such as information relating to donations and donations history, newsletter sign-ups, supporter activity, and participation in updates, initiatives, events, and other outreach or engagement opportunities. If you make a donation, you may also provide payment card or other banking or payment information, which is processed by third-party payment service providers on EarthDNA's behalf. EarthDNA does not store or have access to your payment card or banking information.
- Technological Information, such as Internet Protocol or IP address, browser type, software type, device type, operating system, app version, download date, browsing activity, use of EarthDNA's website and technology systems, cookies, tracking technologies, session identifiers or tokens, scan counts, and other similar technological information.
- Geolocation Information, such as general or approximate location information, including country, city, region, or zip code. EarthDNA does not collect precise geolocation information, such as precise GPS coordinates.
- Security Information. Information relating to access to and use of EarthDNA's physical facilities and technology systems, and other security information.
- Operations Information, such as information EarthDNA processes to conduct its operations, including administration, accounting, legal, compliance, marketing, technology, vendor management, and related operational activities.
- Analytics Information, such as aggregated, de-identified, and other analytical information used for reporting, research, product development, machine learning, artificial intelligence, and business intelligence.
We collect personal information from various sources, including when you use the Services, create an account, fill out a form on our website, sign up for updates, make a donation, upload or submit images or other information, use location-based features, or otherwise interact with us.
2. Sensitive Personal Information and Information about Children
EarthDNA does not intentionally collect sensitive categories of personal information, such as Social Security numbers, government-issued identification numbers, financial account information, health or medical information, biometric information, or information revealing racial or ethnic origin, religious beliefs, sexual orientation, or similar sensitive information.
We do not knowingly collect personal information from anyone under 16 years old (each, a "Child"). If we learn that we have collected or processed a Child's personal information without valid authorization from a parent or legal guardian where required by applicable law, we will take steps to delete that personal information from our systems as soon as reasonably practicable. If you believe that a Child has provided us with personal information, please contact us so that we can investigate and take appropriate action.
3. Use of Artificial Intelligence
EarthDNA's application is an AI-enabled tool that uses artificial intelligence, machine learning, computer vision, and related technologies as a core part of the Services. These technologies are used to analyze images submitted through the application in order to identify shoes, assess shoe condition, estimate value, and support decisions about what to do with shoes next, including donation, resale, recycling, repair, disposal, and related pathways. In connection with this functionality, EarthDNA may process the images you submit, information associated with those images, and certain technological information related to your use of the Services.
If an image you submit contains content other than the shoe or related item, EarthDNA may block the submission or use technical measures to remove, obscure, or minimize background content before processing the image. EarthDNA may use shoe images and associated metadata you provide to train and improve its artificial intelligence and machine learning models. EarthDNA does not use personal information for AI model training.
4. Purposes and Bases for Processing Personal Information
We may process your personal information for the following purposes and bases:
- Consent and Direction. Based on your consent, direction, or other permission you provide to us.
- Provide Services. Activities related to providing Services to you, and improving the Services that we offer and provide.
- Donations, outreach, and engagement. To facilitate donations, supporter activity, newsletter and update subscriptions, initiative participation, and related communications and engagement activity.
- Compliance, safety, claims, and website. To comply with applicable laws and regulations, to protect our rights and interests, to defend against claims, and to monitor, develop, maintain, and protect the operation, security, and integrity of our website, applications, and technology systems.
- Analytics, research, and product development. To analyze, aggregate, deidentify, and otherwise process personal information and other information to develop our Services, and other related initiatives, and to improve and expand our Services and technologies.
- Legitimate Interests. Where processing is necessary for our business operations, such as improving our Services, maintaining security, and operating our business, and where those interests are not overridden by your rights and freedoms.
- Operations. To conduct our internal operations, including administration, accounting, legal, compliance, marketing, technology, and vendor management.
5. Disclosure of Personal Information
EarthDNA may disclose personal information under the following circumstances.
- Consent and Direction. Based on your consent, direction, or other permission you provide to us.
- Provide Services. As necessary to provide the services and related functionality, including to vendors, service providers, contractors, consultants, and other third parties that help us operate our website, application, services, and related programs.
- Donations, outreach, and engagement. To third parties that support donation processing, newsletters, communications, events, initiatives, and related outreach or engagement activities.
- Compliance, safety, claims and legal process. To comply with applicable laws and regulations, protect our rights and interests, defend against claims, and respond to valid legal process or lawful requests from governmental, regulatory, or law enforcement authorities.
- Business Transfers. In anticipation of or in connection with an acquisition, merger, consolidation, restructuring, sale of assets, or other similar corporate transaction.
6. Privacy Rights
Depending on the personal information EarthDNA processes about you, and the manner in which we process such personal information, you may have the following rights with respect to our processing of your personal information.
- Scope of processing. Disclosure about how we process personal information, the categories of personal information we process, and the categories of sources from which such personal information was obtained.
- Access. Access or receipt of a copy of personal information, including (if appropriate) in a portable, machine-readable, and commonly used format.
- Correction. Rectify or correct inaccurate or incomplete personal information.
- Deletion. Deletion or erasure of personal information.
- Restriction. You can request that we limit how your personal information is used in certain situations.
- Objection. Object to our processing of personal information in certain circumstances, including where we process personal information based on legitimate interests or for direct marketing purposes.
- Withdraw consent. Withdraw consent if we rely on consent as the legal basis for processing personal information, provided that such withdrawal will not affect the lawfulness of our processing of personal information before such withdrawal or the continued processing of it after withdrawal for a purpose or basis other than consent.
- Automated decision making. Not be subject, in certain circumstances, to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significantly affects you.
- Selling, profiling, and targeted advertising. Disclosure about whether EarthDNA sells, shares, trades, exchanges, or brokers personal information with or to a third party for the purpose of that or any other third party using the personal information to market on their own behalf, which is referred to as "Selling"; disclosure about whether EarthDNA uses automated decision making to evaluate, analyze or predict personal aspects related to an individual's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, which is referred to as "Profiling"; disclosure about whether EarthDNA targets advertising to individuals based on their activities on unaffiliated third party websites, which is referred to as "Targeted Advertising"; and to object or opt-out of such Selling, Profiling and Targeted Advertising.
To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our website. EarthDNA will respond to all complete requests within 30 days, subject to extension of that period. Also, there may be a delay in processing a request while we verify that the request is valid and originates from a person authorized to make it.
There may be valid reasons that require or permit us to decline to honor a request, in whole or in part, including legal and regulatory requirements that we retain and process certain information. Also, honoring certain requests may limit or prevent us from providing Services to the individual about whom the request is made. In those situations, we will notify you in writing within 30 days, subject to extension of that period. You may also contact our Privacy Officer for information about and help with those situations.
EarthDNA will not discriminate against you for exercising these rights or any other rights under Data Privacy Laws, including by not denying Services to you, not providing a different level or quality of Services, and not suggesting that you will receive a different level or quality of Services.
7. Selling, Profiling, and Targeted Advertising
EarthDNA does not engage in Selling, Profiling, or Targeted Advertising, except with respect to tracking technologies as discussed below.
8. Security
We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We secure the personal information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All personal information is protected using appropriate physical, technical, and organizational measures, which may include encryption in transit and at rest, role-based access controls, access logging, secure cloud storage, and on-device or localized processing of images where appropriate.
9. Website, Cookies, Tracking Technology, and Third Party Tools
EarthDNA may collect and generate information about you when you interact with our website and application, including information about your use of our website and application, such as the pages and features you access, the actions you take, the searches you perform, the content you view, and the information you submit.
When you visit EarthDNA's website, we may place a cookie (a text file containing a randomly assigned number) or a similar technology on your device so we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, we may also collect other information about your use of the website, including your Internet Protocol or IP address, username, session, browser, web pages you view and referring web pages, when you access the website, and general online behavior for performance and marketing purposes.
EarthDNA may use third-party analytics tracking technologies and tools to collect information about how you use our website, such as the frequency of visits, pages viewed, traffic data, location, referring and exit pages, and error information. These tools may also collect device-specific data, including your IP address, operating system, browser type, and Internet connection details. These tools examine website activities to prepare usage reports, and this information helps us improve our website and enhance user experience. Tracking information will be shared with the third-party analytics provider, which may use that information for its own purposes, potentially including marketing or advertising. While the tracking information we collect through such tools is not sufficient on its own for EarthDNA to identify you, the third-party analytics provider may be able to combine it with other data it has to identify you.
If you would like to limit the ability of cookies or tracking technologies and tools to track your activity on our website, you can either configure your preferences for cookie settings on our website, or disable cookies in your Internet browser settings, although doing so may impact the performance and effectiveness of our website or other websites.
10. Duration of Retention
EarthDNA retains personal information only for as long as is necessary or appropriate to achieve the purposes for which such information was collected and processed, unless a longer retention period is required or permitted by applicable law.
11. Automated Decision Making
EarthDNA does not use automated decision making or profiling in the processing of personal information, and does not make decisions that affect you based on automated decision making or profiling using personal information.
12. Changes to Policy
EarthDNA reserves the right to change or amend this privacy policy at any time and for any reason.
13. Questions or Concerns
For questions or concerns, please contact our Privacy Officer as follows.