From ab53822e838920faee9d71f469a7eb5b864d75a4 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Tue, 13 Dec 2022 15:19:22 +0000 Subject: [PATCH 01/14] Add files via upload --- icons/omny.png | Bin 0 -> 764 bytes 1 file changed, 0 insertions(+), 0 deletions(-) create mode 100644 icons/omny.png diff --git a/icons/omny.png b/icons/omny.png new file mode 100644 index 0000000000000000000000000000000000000000..aa59ec34e0e7f2c1e65d18c8bfbd5ae92c2546a3 GIT binary patch literal 764 zcmeAS@N?(olHy`uVBq!ia0vp^3LwnE3?yBabR7dyEa{HEjtmSN`?>!lvI65OJVB zsA8B#ut^}-f;5Aj4RIAvJp=&->(`NPeUO{XWM&%F8U&`Sme#t=^z#}JF&*5Ip?4mk+OG_g*1C@3%Id^d~X?|=JZ zOAWpgfm{D>iN33BZSDJ|sqeCMk6ZJ+%NNCGoU!?LV79N+t)#7tW$jmA7Fn+4vrgC? zb+2-}d+#T%^Q#|(ZmztefA4v_1ji%+F84(jJuFlL3=|H%ul}^rLder=squL+qn9G8 z!X3xuYNomC`L`~LS{kx0L`>N(7xyd}U`_+)o*OxZKFQf6< zrAq2$$`L2TuYSswjA&CvzXj7ahkf6<1%Bv zD~@wTV*YXK1+3`fi$0)pFlW+FpJxkZEKaKv`@MT6_u)88prP02<<6P@b=~Zq m$h>D=a>qAJ3S3JO)o!KbLh*2~7Zbp963J literal 0 HcmV?d00001 From 8860d7ad81cbc0a8908161f24d36c653135077a4 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Tue, 13 Dec 2022 15:43:02 +0000 Subject: [PATCH 02/14] Create omny.toml --- products/omny.toml | 62 ++++++++++++++++++++++++++++++++++++++++++++++ 1 file changed, 62 insertions(+) create mode 100644 products/omny.toml diff --git a/products/omny.toml b/products/omny.toml new file mode 100644 index 00000000..76a22133 --- /dev/null +++ b/products/omny.toml @@ -0,0 +1,62 @@ +name = "OMNY" +description = "OMNY is a public transit payment system in the New York City area" +slug = "omny" +hostnames = [ "omny.info" ] +sources = [ "https://omny.info/privacy-policy/420" ] +contributors = [ "ausernameisnotavailable" ] + +[rubric.behavioral-marketing] +value = "no" +notes = ["No mentioning of any behavioural marketing could be found. Users may recieve non-personalised emails, but may opt-out."] + +[rubric.data-breaches] +value = "no" +citations = ["By using the OMNY Services, you acknowledge and agree that there is a risk that unauthorized third parties may engage in illegal activity, such as hacking or intercepting transmissions of Personal Information. You agree that the MTA is not responsible for any data or Personal Information obtained"] +notes = ["OMNY does not accept responsibility in the event of a data breach, meaning they are unlikely to notify their users."] + +[rubric.data-collection-reasoning] +value = "mostly" +citations = ["We use information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this OMNY Privacy Policy and the OMNY Terms of Service. More specifically, we use the information we collect for the following purposes:"] +notes = ["They list what the data is used for, although there is no reason that they should need to be collecting 'Online Activity Information'"] + +[rubric.data-deletion] +value = "yes-contact" +citations = ["An OMNY Account may be closed at any time by contacting OMNY Customer Service at (877) 789-OMNY (6669) or https://www.omny.info/Contact."] + +[rubric.history] +value = "last-modified" +citations = ["OMNY Privacy Policy Revised June 7, 2022"] +notes = ["The date of latest modification is stated at the top of the page. The previous version(s) are not available."] + +[rubric.law-enforcement] +value = "always" +citations = ["We may be required to share your Personal Information pursuant to a court order or other legal or regulatory obligation or process."] + +[rubric.list-collected] +value = "exhaustively" +citations = ["We collect a few categories of information via our OMNY Services:"] +notes = ["A full list of data collected is available."] + +[rubric.noncritical-purposes] +value = "opt-out-some" +citations = ["Certain OMNY Services, such as the Website and OMNY App, may request your current location, which, if selected, could determine your geographic location. We will only collect and process such information if you have consented and opted-in to this feature. You may also always opt out or withdraw your permission by changing your permissions or settings on your browser or on the OMNY App.", "If we choose to send to you, or you have elected to receive, bulletins, updates, questionnaires, surveys, or other marketing-related materials, we will provide you with the ability to decline – or "opt out" – of receiving such communications."] +notes = ["Opt-out methods are only specified for location and email marketing."] + +[rubric.revision-notify] +value = "no" +citations = ["We may update this OMNY Privacy Policy from time to time. If we make changes to this OMNY Privacy Policy, then we will post them on the Website and indicate the Effective Date. Your continued use of the OMNY Services constitutes your agreement with this OMNY Privacy Policy and any updates to it."] +notes = ["You would need to check the website to find if the privacy policy had been modified."] + +[rubric.security] +value = "somewhat" +citations = ["We have implemented physical, technical, and administrative security measures and controls designed to prevent unauthorized access to, or disclosure of, Personal Information that you provide to us. Additionally, we require our third party providers to implement security measures and to otherwise handle Personal Information consistent with this OMNY Privacy Policy and applicable law. Our security measures and other safeguards are intended to deter and prevent hackers and others from unauthorized access to information that you provide to us."] +notes = ["Very vague."] + +[rubric.third-party-access] +value = "yes-unspecified" +citations = ["We may share your Personal Information among our affiliates and subsidiaries for purposes consistent with this OMNY Privacy Policy."] + +[rubric.third-party-collection] +value = "no" +citations = ["If we collect other information about you using a method that is not specifically listed here, then we will use it in accordance with this OMNY Privacy Policy."] +notes = ["No specific mentioning of third-party data collection, although they do state they they may collect data from other methods that have not been listed."] From b4fd407d6584777d25577f1dcbef53aae98a4fd7 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Tue, 13 Dec 2022 15:43:54 +0000 Subject: [PATCH 03/14] Update omny.toml From 6d6c9203c07ba5210ea7d8f852d937c8fec16939 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Tue, 13 Dec 2022 15:45:35 +0000 Subject: [PATCH 04/14] Fix formatting issues in omny.toml --- products/omny.toml | 2 +- 1 file changed, 1 insertion(+), 1 deletion(-) diff --git a/products/omny.toml b/products/omny.toml index 76a22133..47c68a58 100644 --- a/products/omny.toml +++ b/products/omny.toml @@ -39,7 +39,7 @@ notes = ["A full list of data collected is available."] [rubric.noncritical-purposes] value = "opt-out-some" -citations = ["Certain OMNY Services, such as the Website and OMNY App, may request your current location, which, if selected, could determine your geographic location. We will only collect and process such information if you have consented and opted-in to this feature. You may also always opt out or withdraw your permission by changing your permissions or settings on your browser or on the OMNY App.", "If we choose to send to you, or you have elected to receive, bulletins, updates, questionnaires, surveys, or other marketing-related materials, we will provide you with the ability to decline – or "opt out" – of receiving such communications."] +citations = ["Certain OMNY Services, such as the Website and OMNY App, may request your current location, which, if selected, could determine your geographic location. We will only collect and process such information if you have consented and opted-in to this feature. You may also always opt out or withdraw your permission by changing your permissions or settings on your browser or on the OMNY App.", "If we choose to send to you, or you have elected to receive, bulletins, updates, questionnaires, surveys, or other marketing-related materials, we will provide you with the ability to decline – or 'opt out' – of receiving such communications."] notes = ["Opt-out methods are only specified for location and email marketing."] [rubric.revision-notify] From f644c70aadd6041cc4280ed9038ac65ed249c9ae Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Tue, 13 Dec 2022 15:52:48 +0000 Subject: [PATCH 05/14] Added ausernameisnotavailable --- CONTRIBUTORS.toml | 3 +++ 1 file changed, 3 insertions(+) diff --git a/CONTRIBUTORS.toml b/CONTRIBUTORS.toml index b54d352d..b6d9307c 100644 --- a/CONTRIBUTORS.toml +++ b/CONTRIBUTORS.toml @@ -180,3 +180,6 @@ github = "Dev-Okula" github = "davidbernau" [kelplover] + +[ausernameisnotavailable] +github = "ausernameisnotavailable" From fbcbd292442e01d1eb3f85e2ef2ad4ca7544a6b9 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Wed, 14 Dec 2022 13:16:50 +0000 Subject: [PATCH 06/14] Added Nebula logo --- icons/nebula.png | Bin 0 -> 5157 bytes 1 file changed, 0 insertions(+), 0 deletions(-) create mode 100644 icons/nebula.png diff --git a/icons/nebula.png b/icons/nebula.png new file mode 100644 index 0000000000000000000000000000000000000000..f8bac5fb2de4176a325b82101f45a455854ff0f6 GIT binary patch literal 5157 zcmV+=6x!>FP)@B)speC;p3jpJ@!d0&Co?>m1Ncs9q}#+%;o?YA|a_UY61 z5RSRrX5+Z)DzD#lZV2O9&BPZTPCOFW=a?DKy?p!XNl(Ax%J$(m{Q3FEX4m$w=a{oQ zKkxmlgU#u-Pi_j|b!4!2i4R5P;lOJ-Cbs_QwSQ$^?L|8!ZaZEp${qTr0N>3qm(RR+ zpLH;N4j0BFzRLn~aGQ(4%ME_CI!^$^EoAf8UTMu3-4KVH-O*gW^&c9yzvXn>vL_;H6G5q zitQ?P<_))-&z=E1iZx(==S$zlx;X!!yM5s$_}x^61Y;6`Py*W_^cg(Xm+=!o;s2An zJ?)LT!q1GOeh|XRj-{5KAiQ$cdv34(OMu^D4dm4_vo7|HKc3Jf8K*%6B21WpCY*i! 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T|3u#^00000NkvXXu0mjf4N!74 literal 0 HcmV?d00001 From d49136b514254cf20516712dc80974a39606a11a Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Wed, 14 Dec 2022 13:34:28 +0000 Subject: [PATCH 07/14] Create nebula.toml --- products/nebula.toml | 60 ++++++++++++++++++++++++++++++++++++++++++++ 1 file changed, 60 insertions(+) create mode 100644 products/nebula.toml diff --git a/products/nebula.toml b/products/nebula.toml new file mode 100644 index 00000000..4ca02dfe --- /dev/null +++ b/products/nebula.toml @@ -0,0 +1,60 @@ +name = "Nebula" +description = "Nebula is a creator-owned video streaming platform" +slug = "nebula" +hostnames = [ "nebula.tv" ] +sources = [ "https://nebula.tv/privacy", "https://nebula.tv" ] +contributors = [ "ausernameisnotavailable" ] + +[rubric.behavioral-marketing] +value = "no" +citations = ["and no ads in sight."] +notes = ["They do not mention behavioral marketing in their privacy-policy, although on their homepage, they state that they do not have any adverts."] + +[rubric.data-breaches] +value = "no" +notes = ["There is nothing in their privacy policy that would require them to notify users of a data breach."] + +[rubric.data-collection-reasoning] +value = "no" +citations = ["We will not collect any more information than needed to provide you with a great experience."] +notes = ["It is unclear what they mean by providing users with a great experience."] + +[rubric.data-deletion] +value = "yes-automated" +citations = ["If you want to cancel your subscription, that’s okay. No hard feelings. We’ll remove your data as soon as possible. It may take a while because backups, but we won’t put any artificial delays in place."] +notes = ["You may need to cancel your subscription, then press a separate delete account button to close your account."] + +[rubric.history] +value = "no" +notes = ["No mention of any previous versions could be found."] + +[rubric.law-enforcement] +value = "strict" +citations = ["We won’t share any data with government or law enforcement unless required to by law."] + +[rubric.list-collected] +value = "no" +citations = ["We will not collect any more information than needed to provide you with a great experience."] +notes = ["This is the only mentioning of what data is collected."] + +[rubric.noncritical-purposes] +value = "na" +citations = ["We will not collect any more information than needed to provide you with a great experience."] +notes = ["Data is only collected to provide what is described as a great experience. It is unclear what this means."] + +[rubric.revision-notify] +value = "yes" +citations = ["We may occasionally need to change this policy. We’ll be sure to let you know. This might require us sending you an annoying email."] + +[rubric.security] +value = "no" +notes = ["Nothing about security is mentioned."] + +[rubric.third-party-access] +value = "yes-unspecified-critical" +citations = ["Whatever information we collect, we won’t share with third parties beyond the technical requirements of third-party services.","We don't have your credit card information. Our processing partner, Stripe, does."] +notes = ["Other than Stripe, no other third-parties are specified, but only critical providers are used."] + +[rubric.third-party-collection] +value = "no" +notes = ["Nothing regarding how data is collected was specified."] From db61df79a742a94bc783362ae888aa61cf31b33d Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Wed, 14 Dec 2022 15:33:18 +0000 Subject: [PATCH 08/14] Update nebula.toml --- products/nebula.toml | 5 ++--- 1 file changed, 2 insertions(+), 3 deletions(-) diff --git a/products/nebula.toml b/products/nebula.toml index 4ca02dfe..3414d871 100644 --- a/products/nebula.toml +++ b/products/nebula.toml @@ -2,13 +2,12 @@ name = "Nebula" description = "Nebula is a creator-owned video streaming platform" slug = "nebula" hostnames = [ "nebula.tv" ] -sources = [ "https://nebula.tv/privacy", "https://nebula.tv" ] +sources = [ "https://nebula.tv/privacy" ] contributors = [ "ausernameisnotavailable" ] [rubric.behavioral-marketing] value = "no" -citations = ["and no ads in sight."] -notes = ["They do not mention behavioral marketing in their privacy-policy, although on their homepage, they state that they do not have any adverts."] +citations = ["Whatever information we collect, we won’t share with third parties beyond the technical requirements of third-party services."] [rubric.data-breaches] value = "no" From 6b61ab3744bc50e34fc951a1000fa73fe9e939f6 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Wed, 14 Dec 2022 15:39:27 +0000 Subject: [PATCH 09/14] Update omny.toml --- products/omny.toml | 10 +++++----- 1 file changed, 5 insertions(+), 5 deletions(-) diff --git a/products/omny.toml b/products/omny.toml index 47c68a58..f11e535c 100644 --- a/products/omny.toml +++ b/products/omny.toml @@ -2,12 +2,12 @@ name = "OMNY" description = "OMNY is a public transit payment system in the New York City area" slug = "omny" hostnames = [ "omny.info" ] -sources = [ "https://omny.info/privacy-policy/420" ] +sources = [ "https://omny.info/privacy-policy" ] contributors = [ "ausernameisnotavailable" ] [rubric.behavioral-marketing] -value = "no" -notes = ["No mentioning of any behavioural marketing could be found. Users may recieve non-personalised emails, but may opt-out."] +value = "yes" +citations = ["We use information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this OMNY Privacy Policy and the OMNY Terms of Service. More specifically, we use the information we collect for the following purposes:...to perform analytics, quality control, market research, and to determine the effectiveness of our OMNY Services, promotional campaigns, to improve our current products, OMNY Services, and develop new products and services;...In addition to the uses specifically identified above, there may be instances where you request information and OMNY Services from us that are not described in this OMNY Privacy Policy."] [rubric.data-breaches] value = "no" @@ -17,7 +17,7 @@ notes = ["OMNY does not accept responsibility in the event of a data breach, mea [rubric.data-collection-reasoning] value = "mostly" citations = ["We use information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this OMNY Privacy Policy and the OMNY Terms of Service. More specifically, we use the information we collect for the following purposes:"] -notes = ["They list what the data is used for, although there is no reason that they should need to be collecting 'Online Activity Information'"] +notes = ["They list what the data is used for, although there is no reason that they should need to be collecting Online Activity Information, which is defined as device-related information, such as cookies and IP addresses."] [rubric.data-deletion] value = "yes-contact" @@ -29,7 +29,7 @@ citations = ["OMNY Privacy Policy Revised June 7, 2022"] notes = ["The date of latest modification is stated at the top of the page. The previous version(s) are not available."] [rubric.law-enforcement] -value = "always" +value = "strict" citations = ["We may be required to share your Personal Information pursuant to a court order or other legal or regulatory obligation or process."] [rubric.list-collected] From 6476a3107edb9cc7a98f7423605e0a8fbe005c46 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Fri, 16 Dec 2022 12:35:09 +0000 Subject: [PATCH 10/14] Update nebula.toml --- products/nebula.toml | 2 +- 1 file changed, 1 insertion(+), 1 deletion(-) diff --git a/products/nebula.toml b/products/nebula.toml index 3414d871..ea0670a2 100644 --- a/products/nebula.toml +++ b/products/nebula.toml @@ -37,7 +37,7 @@ citations = ["We will not collect any more information than needed to provide yo notes = ["This is the only mentioning of what data is collected."] [rubric.noncritical-purposes] -value = "na" +value = "no" citations = ["We will not collect any more information than needed to provide you with a great experience."] notes = ["Data is only collected to provide what is described as a great experience. It is unclear what this means."] From 7e0d931c02337828559773df5f9b66ec29b9ce83 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Fri, 16 Dec 2022 12:36:13 +0000 Subject: [PATCH 11/14] Update omny.toml --- products/omny.toml | 5 +---- 1 file changed, 1 insertion(+), 4 deletions(-) diff --git a/products/omny.toml b/products/omny.toml index f11e535c..8a7e59bd 100644 --- a/products/omny.toml +++ b/products/omny.toml @@ -1,5 +1,5 @@ name = "OMNY" -description = "OMNY is a public transit payment system in the New York City area" +description = "OMNY is a public transit payment system in the New York City area." slug = "omny" hostnames = [ "omny.info" ] sources = [ "https://omny.info/privacy-policy" ] @@ -12,7 +12,6 @@ citations = ["We use information that we collect or process, including Personal [rubric.data-breaches] value = "no" citations = ["By using the OMNY Services, you acknowledge and agree that there is a risk that unauthorized third parties may engage in illegal activity, such as hacking or intercepting transmissions of Personal Information. You agree that the MTA is not responsible for any data or Personal Information obtained"] -notes = ["OMNY does not accept responsibility in the event of a data breach, meaning they are unlikely to notify their users."] [rubric.data-collection-reasoning] value = "mostly" @@ -45,12 +44,10 @@ notes = ["Opt-out methods are only specified for location and email marketing."] [rubric.revision-notify] value = "no" citations = ["We may update this OMNY Privacy Policy from time to time. If we make changes to this OMNY Privacy Policy, then we will post them on the Website and indicate the Effective Date. Your continued use of the OMNY Services constitutes your agreement with this OMNY Privacy Policy and any updates to it."] -notes = ["You would need to check the website to find if the privacy policy had been modified."] [rubric.security] value = "somewhat" citations = ["We have implemented physical, technical, and administrative security measures and controls designed to prevent unauthorized access to, or disclosure of, Personal Information that you provide to us. Additionally, we require our third party providers to implement security measures and to otherwise handle Personal Information consistent with this OMNY Privacy Policy and applicable law. Our security measures and other safeguards are intended to deter and prevent hackers and others from unauthorized access to information that you provide to us."] -notes = ["Very vague."] [rubric.third-party-access] value = "yes-unspecified" From e63ab3cce0eeb601904ca18ad144b7c3cbd5b766 Mon Sep 17 00:00:00 2001 From: ausernameisnotavailable <120484856+ausernameisnotavailable@users.noreply.github.com> Date: Fri, 16 Dec 2022 16:52:26 +0000 Subject: [PATCH 12/14] Update nebula.toml --- products/nebula.toml | 2 +- 1 file changed, 1 insertion(+), 1 deletion(-) diff --git a/products/nebula.toml b/products/nebula.toml index ea0670a2..5915b5a2 100644 --- a/products/nebula.toml +++ b/products/nebula.toml @@ -1,5 +1,5 @@ name = "Nebula" -description = "Nebula is a creator-owned video streaming platform" +description = "Nebula is a creator-owned video streaming platform." slug = "nebula" hostnames = [ "nebula.tv" ] sources = [ "https://nebula.tv/privacy" ] From 9bf06eecaec0909552b7fffbc680e11887f0880b Mon Sep 17 00:00:00 2001 From: Matthew RONCHETTO Date: Mon, 9 Sep 2024 12:09:49 -0700 Subject: [PATCH 13/14] fix(product): changes to OMNY - Fix TOML formatting - Improve line formatting - Fix score for list-collected --- products/omny.toml | 8 ++++---- 1 file changed, 4 insertions(+), 4 deletions(-) diff --git a/products/omny.toml b/products/omny.toml index 8a7e59bd..b1f94a99 100644 --- a/products/omny.toml +++ b/products/omny.toml @@ -3,11 +3,11 @@ description = "OMNY is a public transit payment system in the New York City area slug = "omny" hostnames = [ "omny.info" ] sources = [ "https://omny.info/privacy-policy" ] -contributors = [ "ausernameisnotavailable" ] +contributors = [ "ausernameisnotavailable", "doamatto" ] [rubric.behavioral-marketing] value = "yes" -citations = ["We use information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this OMNY Privacy Policy and the OMNY Terms of Service. More specifically, we use the information we collect for the following purposes:...to perform analytics, quality control, market research, and to determine the effectiveness of our OMNY Services, promotional campaigns, to improve our current products, OMNY Services, and develop new products and services;...In addition to the uses specifically identified above, there may be instances where you request information and OMNY Services from us that are not described in this OMNY Privacy Policy."] +citations = ["We use information that we collect or process, including Personal Information, Online Activity Information, and Anonymous Information, as permitted under applicable law and consistent with this OMNY Privacy Policy and the OMNY Terms of Service. More specifically, we use the information we collect for the following purposes: ... to perform analytics, quality control, market research, and to determine the effectiveness of our OMNY Services, promotional campaigns, to improve our current products, OMNY Services, and develop new products and services;...In addition to the uses specifically identified above, there may be instances where you request information and OMNY Services from us that are not described in this OMNY Privacy Policy."] [rubric.data-breaches] value = "no" @@ -32,7 +32,7 @@ value = "strict" citations = ["We may be required to share your Personal Information pursuant to a court order or other legal or regulatory obligation or process."] [rubric.list-collected] -value = "exhaustively" +value = "generally" citations = ["We collect a few categories of information via our OMNY Services:"] notes = ["A full list of data collected is available."] @@ -54,6 +54,6 @@ value = "yes-unspecified" citations = ["We may share your Personal Information among our affiliates and subsidiaries for purposes consistent with this OMNY Privacy Policy."] [rubric.third-party-collection] -value = "no" +value = "no" citations = ["If we collect other information about you using a method that is not specifically listed here, then we will use it in accordance with this OMNY Privacy Policy."] notes = ["No specific mentioning of third-party data collection, although they do state they they may collect data from other methods that have not been listed."] From 67b1e077376904cadcdb655d310686c1039544fc Mon Sep 17 00:00:00 2001 From: Matthew RONCHETTO Date: Mon, 9 Sep 2024 12:12:45 -0700 Subject: [PATCH 14/14] fix(product): changes to Nebula - Updated score and citation behavioral-marketing (no -> yes-opt-out) - Updated citation for data-breaches - Updated data-collection-reasoning (no -> mostly) - Updated citation for data-deletion - Updated score and citation for history (no -> last-modified) - Updated score and citation for law-enforcement (strict -> reasonable) - Updated score and citation for list-collected (no -> generally) - Updated score and citation for noncritical-purposes (no -> opt-out-some) - Updated citation for revision-notify - Updated score and citation for security (no -> somewhat) - Updated score and citation for third-party-access (yes-unspecified-critical -> yes-unspecified) - Updated score and citation for third-party-collection (no -> yes) --- products/nebula.toml | 102 ++++++++++++++++++++++++++++++++----------- 1 file changed, 77 insertions(+), 25 deletions(-) diff --git a/products/nebula.toml b/products/nebula.toml index 5915b5a2..e10f6195 100644 --- a/products/nebula.toml +++ b/products/nebula.toml @@ -3,57 +3,109 @@ description = "Nebula is a creator-owned video streaming platform." slug = "nebula" hostnames = [ "nebula.tv" ] sources = [ "https://nebula.tv/privacy" ] -contributors = [ "ausernameisnotavailable" ] +contributors = [ "ausernameisnotavailable", "doamatto" ] [rubric.behavioral-marketing] -value = "no" -citations = ["Whatever information we collect, we won’t share with third parties beyond the technical requirements of third-party services."] +value = "yes-opt-out" +citations = ["We may work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you ... over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you."] [rubric.data-breaches] value = "no" -notes = ["There is nothing in their privacy policy that would require them to notify users of a data breach."] +citations = ["In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law."] +notes = ["Although some people may be able to receive such notifications, it is not guaranteed for all users."] [rubric.data-collection-reasoning] -value = "no" -citations = ["We will not collect any more information than needed to provide you with a great experience."] +value = "mostly" +citations = [ + "We use personal information to provide the Services and for purposes that you reasonably expect.", + """ + We may use personal information to provide our Services and operate our business. For example, we use personal information to: + - fulfill your requests for selecting and purchasing merch and subscriptions; + - establish, manage, monitor, and maintain your account on our Platform; + - improve and personalize your experience on or with the Services; + - verify your identity or determine your eligibility for offers and promotions; + - communicate with you, including providing notices about your account or transaction, and responding to any of your requests or questions; + - provide any surveys, contests, or promotions that you participate in; + - provide maintenance and support; and + - fulfill any other purpose for which you provide personal information. + """, + "We use personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services.", + "We may work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services.", + "We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.", + "We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services and our products and services, business, databases, and other technology assets; (b) protect our, your, or others' rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.", + "We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law." +] notes = ["It is unclear what they mean by providing users with a great experience."] [rubric.data-deletion] value = "yes-automated" -citations = ["If you want to cancel your subscription, that’s okay. No hard feelings. We’ll remove your data as soon as possible. It may take a while because backups, but we won’t put any artificial delays in place."] -notes = ["You may need to cancel your subscription, then press a separate delete account button to close your account."] +citations = ["If you wish to delete your account with us, you may do so by logging into your account and selecting \"Delete account\"."] [rubric.history] -value = "no" -notes = ["No mention of any previous versions could be found."] +value = "last-modified" +citations = [ "Last updated: August 31, 2023" ] [rubric.law-enforcement] -value = "strict" -citations = ["We won’t share any data with government or law enforcement unless required to by law."] +value = "reasonable" +citations = ["Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency)."] [rubric.list-collected] -value = "no" -citations = ["We will not collect any more information than needed to provide you with a great experience."] +value = "generally" +citations = [ + """ + Personal information you provide to us through the Services, such as when you purchase a subscription or merchandise, contact us (including by social media), participate in an online survey, or otherwise, may include the following categories. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. + + Contact details, such as your first and last name, email and mailing addresses, and phone number. + Account information, such as your username (email address) and password that you set to establish an online account with us, your watch history, preferences, and other details about your use of the Services. + Payment and transactional data, such as the information needed to complete your merch orders and subscriptions on or through our Platform (all payment processing services connected with your use of the Platform are provided to you by our third-party payment processor), and records of merch and subscriptions you have purchased from us. + Marketing preferences, such as your preferences for receiving communications about Nebula content, merch, activities, events, publications, and related services, and details about how you engage with our communications. + Survey responses, such as the information you provide in response to our surveys, questionnaires, or contests. + Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us, or otherwise. + """, + """ + Nebula, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Services and other sites and online services. Personal information that may be automatically collected includes: + + Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, general location information such as city, state or geographic area; and + Online activity information, such as information about your use of and actions on the Services, such as the website you visited before browsing to our Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. + """, + "Nebula may receive personal information about you from other third-party sources, including from our service providers, data analytics partners, social media platforms, advertising partners, business partners, data providers, publicly available sources, and third party APIs. We may merge or combine such personal information with the personal information we collect from you directly or automatically." +] notes = ["This is the only mentioning of what data is collected."] [rubric.noncritical-purposes] -value = "no" -citations = ["We will not collect any more information than needed to provide you with a great experience."] -notes = ["Data is only collected to provide what is described as a great experience. It is unclear what this means."] +value = "opt-out-some" +citations = [ + "The Nebula Store uses Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.", + "You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Users of our Mobile Application may opt out of receiving targeted advertising in through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user's choices." +] [rubric.revision-notify] value = "yes" -citations = ["We may occasionally need to change this policy. We’ll be sure to let you know. This might require us sending you an annoying email."] +citations = ["Nebula reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Services, or other means as may be required by applicable law."] [rubric.security] -value = "no" -notes = ["Nothing about security is mentioned."] +value = "somewhat" +citations = [ + "We build security into our Platform that is designed to protect your personal information, but no method over the Internet is fully secure.", + "No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law." +] [rubric.third-party-access] -value = "yes-unspecified-critical" -citations = ["Whatever information we collect, we won’t share with third parties beyond the technical requirements of third-party services.","We don't have your credit card information. Our processing partner, Stripe, does."] -notes = ["Other than Stripe, no other third-parties are specified, but only critical providers are used."] +value = "yes-unspecified" +citations = [ + "We share personal information as necessary to provide the Services and for purposes described elsewhere in this Privacy Policy or at the time of collection, including with related companies, service providers, advertising partners (including for interest-based advertising), and to law enforcement, authorities, and other third parties as may be necessary for compliance, fraud prevention, safety, or in the event of a business transaction.", + "We may share your personal information with our affiliates, subsidiaries, and other related companies.", + "We may share your personal information with the Nebula community of digital video creators and podcasters.", + "We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with services providers who help us perform e-commerce and product fulfillment, billing, payment processing, website hosting, app design, maintenance services, database management, web analytics, app analytics, fraud protection, credit risk reduction, marketing, and other purposes.", + "We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the \"Interest-Based Advertising\" section above.", + "We may share personal information with persons, companies, or professional firms providing Nebula with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.", + "Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).", + "We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled \"Compliance, Fraud Prevention, and Safety.\"", + "We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings)." +] [rubric.third-party-collection] -value = "no" -notes = ["Nothing regarding how data is collected was specified."] +value = "yes" +citations = [ + "Nebula may receive personal information about you from other third-party sources, including from our service providers, data analytics partners, social media platforms, advertising partners, business partners, data providers, publicly available sources, and third party APIs. We may merge or combine such personal information with the personal information we collect from you directly or automatically." +]