Effective date: June 1, 2020
Last Revision: January 25, 2023

1. OVERVIEW

This privacy policy describes how Safe Conversations LLC (“we,”“our,” “us”) maintains, uses and shares information that we may collect when you use our website at www.safeconversations.com (the “Site”), our mobile application(s) (the “App”) and any other programs, presentations, workshops, courses, events, information, materials, products or services that we may offer from time to time by means of the Site or the App (collectively, together with the Site and the App, the “Services”).
We may change this privacy policy from time to time. Any such changes will be posted here. If we make a material change in the way we use your Personal Data (as defined below), we will prominently note the change on the Services.

2. WHAT PERSONAL DATA WE COLLECT
Some of the information we may collect when you use the Services, such as your name, postal address, email address or telephone number, or, if you buy something, your credit/debit card or other payment information, may allow you to be identified. We call this information, and other information which relates to you individually, “Personal Data.”

3. HOW WE COLLECT AND USE PERSONAL DATA
(a) Inquiries. If you send us a comment or question or make an inquiry to customer support, we will retain the information that you provide to us for the purpose of responding to you, as well as for improving the Services.
(b) Registrations. We may give you additional opportunities to provide Personal Data, whether to register for or participate in one of our Services or for other purposes. In such cases, we will use this Personal Data for the purposes specified when you provide such information or as otherwise provided in this Policy. In addition, we may use email addresses of registrants for Services to provide electronic newsletters that we believe will be of interest. Any such newsletters will include a means to unsubscribe from receiving additional such communications. We may also use and disclose such information in aggregate form, so that individuals are not identifiable, in connection with grant applications and donor reports.
(c) Workshops. If you participate in a workshop to become a trainer, we may include your contact information in a directory of participants in such programs, which we may make available to other trainers, trainees, administrators, and workshop participants.
(d) Visitors. If you are just visiting the Services and not requesting information, making a purchase, contacting us, or otherwise voluntarily submitting Personal Data, we do not ordinarily collect any Personal Data about you except through web logs, as described below. In that case, we obtain the information that you provide and will use it to respond to your inquiry or request. We do not share any of this information with anyone else, except to respond to your request, if you consent, or as otherwise described in this privacy policy.
(e) e-Commerce. If you pay for something on the Services, and you furnish your credit/debit card number or other payment information for such purpose, we will only use this information to fulfill your purchase.
(f) Web Logs. We maintain web logs that automatically record basic information about everyone who visits the Services. We use web log information to help us design our website, to identify popular features, to improve our services, and for other managerial and analytic purposes. These logs contain:

• The Internet domain from which you access the Services.
• Your IP address.
• The type of browser and operating system that you use.
• The date and time you visited the Services.
• The pages that you visited on the Services.
• The address of the website you linked from to get to the Services.

(g) Cookies. We use cookies and may use similar technologies to help you navigate the Services, to allow us to learn how you use the Services, and to improve the Services. Cookies are text files we place in your computer’s browser to store your preferences. Cookies, by themselves, do not reveal any Personal Data unless you choose to provide this information to us by, for example, making a purchase. From time to time, we may engage third parties to track and analyze usage and volume of statistical information from individuals who visit the Services. If we do so, the information provided to such third parties will not include Personal Data. The use of cookies by any partners or service providers is not covered by our privacy statement. We will not have access to, or control over, these cookies.
(h) Links to Other Websites. The Services may include links to other websites whose privacy practices differ from ours. If you submit Personal Data to any of those sites, your information will be governed by their privacy policies.
(i) Communicating with You. We may use your Personal Data for the purpose of communicating with you and responding to your inquiries.
(j) Affiliates. We may share your Personal Data with our affiliated organizations or their principals to allow them to communicate with you about matters that we believe may be of interest to you.
(k) Service Providers. We at times contract with third-party service providers to perform functions for us. These service providers may be given access to the information we collect for the purpose of performing those functions, but they will be contractually bound to maintain the confidentiality of the information and not to use it for any other purpose.
(l) Chatrooms, Blogs or other Forums. We may provide an opportunity for you to post information to a chatroom or forum, as a comment to a blog entry or by means of other publicly accessible areas of the Services. If we do so, any information that you provide may be publicly displayed. We urge you not to provide any Personal Data, including any information regarding health or medical matters, or anything else that you wish to remain private, in such a context.
(m) Surveys. We may ask you to complete surveys or opinion polls from time to time. Participation is voluntary. We only use and publicly disclose the information that we collect from surveys or polls in an aggregate manner, not in individually identifiable form, for purposes of research, fundraising and education and to allow us to improve our Services and how we serve our constituency.
(n) Social Media; Streaming. The Services may include social media features, such as links that allow you to follow us on Facebook. These features may collect information about your IP address and which page you are visiting on the Services, and they may set a cookie to make sure the feature functions properly. You may also be able to view Content by means of Facebook or another social media service, or through a third party streaming platform such as Roku or YouTube. Your interactions with these features are subject to the privacy policies of the companies that provide them.
(o) Geolocation. If you use a mobile device to access the Services, we may collect certain additional information. We may receive information about your location and your mobile device, including a unique identifier for your device, your mobile operating system, and the type of mobile Internet browser that you use. We may use this information for research purposes or to facilitate providing you with services. Most mobile devices provide users with the ability to disable location services.
(p) Business Transfers. If we were to transfer all or substantially all of our assets to another organization, one of the assets we would likely include in the transfer is our database of Personal Data.
(q) Disclosures for Legal Reasons. We will disclose Personal Data when we are required to do so by law, regulation or securities exchange requirements, for example, in response to a court order or subpoena. We also may disclose such information in response to a law enforcement agency’s request or when we believe such disclosure is appropriate to protect our legal rights or to safeguard anyone’s property or safety.

4. YOUR PRIVACY CHOICES
If you would like us to stop sending you email or other communications or would like to access your registration information to correct or delete it, you may send us a request using the contact information at the end of this Privacy Policy. We will fulfill any opt-out requests within ten (10) business days. We take reasonable steps to ensure that the information we collect is reliable for its intended use, accurate, complete and current.

5. YOUR RIGHTS
Residents of the European Union have certain rights, as provided by applicable law, which include the rights to: (i) request confirmation of whether we store, use or share any of your personal data; (ii) obtain access to or a copy of your personal data; (iii) receive an electronic copy of personal data that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal data or object to those uses; (v) seek correction of inaccurate, untrue or incomplete personal data; or (vi) request erasure of personal data held about you by us, subject to certain exceptions prescribed by law.
Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. However, withdrawing consent will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like to exercise any of these rights, please contact us at the email or physical address set out below. You will not have to pay a fee to exercise any of these rights.
In addition, if you are a resident of the European Union, you have the right to complain to a Data Protection Authority if you believe that your personal data has been collected or used in violation of relevant privacy requirements.

6. RETAINING AND DELETING PERSONAL DATA
We retain personal data that we collect no longer than is reasonably necessary to fulfill the purposes for which we collect the information and to comply with our legal obligations.

7. INTERNATIONAL TRANSFERS
We are headquartered in the United States. Your information will likely be collected in the country where you reside and, if that is outside the United States, will be subsequently transferred or stored in the United States. In accordance with applicable law, we implement measures to ensure that any transferred personal data remains protected and secure. You can obtain further information about these measures by contacting us using the contact details set out below.

8. AUTOMATED PROCESSING
We do not use your personal data to make automated decisions about you without any human input. In we ever begin to do so, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, and request that we restrict the use of your personal data for the purposes of these automated decisions.

9. SPECIAL CATEGORIES OF PERSONAL DATA
We do not, unless you explicitly consent, process any of your personal data in the following special categories: (i) personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic data; (iii) biometric data for the purpose of uniquely identifying you; or (iv) data concerning your health, sex life or sexual orientation.

10. DO NOT TRACK
We do not note if you set your web browser to send a “do not track” or similar request when you visit our Services, and doing so will not affect the performance of the Services.

11. SECURITY
We use reasonable efforts to maintain the security of all Personal Data, including technological safeguards, but cannot guarantee that an unauthorized breach or disclosure of such information could never occur.

12. CHILDREN
The Site and the App are intended for use by adults. Neither the Site nor the App target children under the age of 13, nor do we knowingly collect any Personal Data by means of the Site or the App from children under the age of 13.

13. ACCOUNTABILITY
We are committed to adhering to our privacy policy and applicable laws and to making your online experience secure and valuable. If you have a question, request, complaint, dispute or concern related to this privacy policy, you may send a message by email to info@pomeroylawgroup.com or by postal mail to Pomeroy Law Group PLLC, Attention: Safe Conversations, 305 Broadway, 7th Floor, New York, NY 10007-1188. We will work with you to obtain a prompt resolution of any issues you may have.