Privacy policy | Project Liberty

Last Updated July 23, 2023

This privacy policy (“Privacy Policy”) applies to personal information collected through www.projectliberty.io, and other products and services, including websites, mobile apps, registration forms, and other digital properties, as expressly indicated by Project Liberty such as through a link to or other display of this Privacy Policy (all of the foregoing collectively, this “Site”). By visiting and/or using this Site, you have agreed to this Privacy Policy.

Project Liberty (“we” or “us”) reserves the right to change this Privacy Policy at any time by posting revisions to this Site. Such changes will be effective upon posting. Project Liberty includes DSNP.org LLC, McCourt Institute LLC and Project Liberty UK Services Limited.

We are working very hard to modernize the experience of all users on the Internet to further empower the ability of you, the user, to make privacy decisions yourself through technology—and hopefully thereby making the need to write and read lengthy privacy policies like this one a thing of the past. We are counting on you to help us get there! But until then, here we go.

What personal information do we collect?

Cookies are for eating—not for tracking—but we do appreciate the efficiency of some technological cookies. We do not use tracking cookies or web beacons. We additionally do not use persistent ID cookies on this site except where you click “remember me” or are logged in; we may however use session cookies, which expire when you close your browser, on certain portions of the Site. But you shouldn’t just take our word on our approach to cookies. Most browsers are set to accept cookies by default, but you can usually set your browser to disable cookies, or to alert you when cookies are being sent. You should keep in mind that other websites that you go to from our Site may not share our view of cookies or web beacons.

Other than web logs as described below and session cookies as described above, we only collect personal information through this Site that you choose to share with us (e.g., by signing up for our email list or otherwise filling out a form on our Site). Such personal information may include things like your name, address, e-mail address, affiliated organization and social media handles.

We do use web logs, which automatically collect information about the IP address of your computer, browser type, language, device information, operating system, the state or country from which you accessed this Site, the web pages and content visited, the date and the time of a visit, and the sites you visited immediately before this Site (e.g., a referrer page). This automatically collected data is generally not retained in non-aggregated form for more than 30 days.

We may use Matomo Analytics to improve the Site’s functions. Unlike other data analytics providers, Matomo does not gain ownership of any data it collects or processes from our Site. We retain 100% data ownership. You can choose to not be included in Matomo Analytics by visiting the homepage of our website and selecting the green button in the bottom right hand corner of the screen.

We require that users under 18 years of age or under the age of majority in their jurisdiction not submit personal information. In accordance with the U.S. federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we do not knowingly collect personal information from children under 13 years of age. If we learn that we have collected personal information about a user under 18 years of age, we will immediately delete that information.

Do not provide information about others unless you are authorized to do so and consent to have all information used, disclosed and transferred in accordance with this Privacy Policy. By submitting information about others, you represent and warrant that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

Use and disclosure of personal information

First and most importantly, we do not sell or rent personal information obtained through this Site, and we do not use personal information obtained through this Site to try to sell you anything.

We do, however, use personal information for carefully considered internal purposes, which include some or all of the following:

to communicate with you;

to provide and facilitate our services and products;

to provide you with information regarding the Project Liberty;

to enhance your experience with this Site, including (if you click “remember me” or are logged in) to save your preferences;

to analyze Site usage;

to protect the interests, rights, safety or property of the Project Liberty or others and to monitor compliance with and enforce any terms of any agreement with the Project Liberty; and

to operate our organization and systems properly.

We generally do not share your personal information with any third party (including for marketing, advertising or analytics purposes), and carefully consider each instance in which such information must be shared with third parties. We only share your personal information with:

designated service providers (e.g., our hosting service and email service) for the purposes set out in this Privacy Policy;

third parties if we believe in good faith that such disclosure is necessary:

to comply with the law or in response to a subpoena, court order, government request or other legal process;

to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations or other legal or administrative proceedings;

to protect the interests, rights, safety or property of us, any member of us or others;

to monitor compliance with and enforce any terms of service on this Site; or

to operate the systems that provide our services and products properly.

We are not responsible for the collection, use, or disclosure of your information by affiliates and third parties, including any applications that are provided through the Site. Such collection, use or disclosure by affiliates or third parties (including applications) are governed by their privacy policies. This Privacy Policy expressly does not apply to Unfinished LLC, McCourt Global LLC or any of their respective subsidiaries other than Project Liberty.

If you participate in comment boards or similar public features of this Site, please note that any information you or others voluntarily disclose through use of these features becomes available to the public and/or other users whom you have designated and will be visible to such individuals for their use. We are not responsible for the information that you or others choose to disclose publicly on this Site, and others’ use of such information is not subject to this Privacy Policy.

Any information that we gather from web logs (as described above), we only use for internal purposes such as research, analysis, to better serve visitors to this Site, to compile or use aggregate and anonymous information about usage of this Site and other statistics.

Security and retention of your personal information

Any of your personal information collected by us through this Site is kept on servers using security measures appropriate to the provision of the relevant product or services, such as reasonable administrative, technical, personnel and physical measures to safeguard personal information. The security of your personal information is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

Rights with respect to your personal information

We believe that you, the user, should have the right to:

access, correct, request the deletion or restricted use of, or request that we refrain from processing, personal information of yours that is covered by this Privacy Policy,

request that we disclose to you:

the categories of personal information we have collected about you,

the categories of sources from which the personal information is collected,

the business or commercial purpose for collecting or selling the personal information,

the categories of third parties with whom we have shared the personal information, and

the specific pieces of personal information we have collected about you; and

not receive discriminatory treatment from us for the exercise of any of the foregoing rights.

Laws in certain jurisdictions provide some of the above rights to the residents of those jurisdictions. But we are not limiting the above rights to those residents. The above rights apply to all of our users, regardless of where they are domiciled.

For inquiries about your personal information or this Privacy Policy, or to make a request pursuant to the forgoing paragraph, please either (i) email us at [email protected], or (ii) write to us at Project Liberty, c/o McCourt Global LLC, 540 W 30th Street, Suite 40A, New York, NY 10001. Please include the following information in all requests: first name, last name, e-mail address, physical address (so we can identify the jurisdiction in which you live), description of request being made, and “Privacy” in the subject line. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable law. Please note that it may take some time to process your request, consistent with applicable law.

Process for verifying requests

In order to protect your privacy and security, prior to completing any request that you may submit pursuant to the foregoing, we must verify your identity. We will verify your identity by asking you to provide certain data that we have already collected from you to confirm that they match our records. In certain instances, additional verification steps may be required.

Authorized agents

You may designate an authorized agent to make a request on your behalf pursuant to this Privacy Policy or applicable law. Prior to completing a request made by such an authorized agent, we require that you provide your authorized agent with written permission to submit such a request and require that you or your authorized agent provide us with a copy of such written permission. Additionally, we require that you verify your identity pursuant to the procedure described above.

Transfer of personal information to other countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to the transfer of your information to the United States and other countries around the world that may not guarantee the same level of protection for such information as your country and to the processing of your information in these countries.

Links to third-party sites

This Site may contain links to third-party sites, including to social networking sites. We are not responsible for any personal information you may provide while on such sites. Any information provided on such sites is governed by the privacy policies of the third-party sites.

Questions regarding this privacy policy

If you have questions regarding this Privacy Policy, please contact us at [email protected].