Last updated: April 16, 2020
Caboodle (“us”, “we”, or “our”) operates the Caboodle website (the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
Information Collection And Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:
- Email address
- Telephone number
We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
The security of your Personal Information is important to us, but 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.
Links To Other Sites
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our servers immediately.
Data Retention Policy
Caboodle Media Ltd. Co. seeks to ensure that it retains only data necessary to effectively conduct its program activities and work in fulfillment of its mission.
The need to retain data varies widely with the type of data and the purpose for which it was collected. Caboodle Media Ltd. Co. strives to ensure that data is only retained for the period necessary to fulfill the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth Caboodle Media Ltd. Co.’s guidelines on data retention and is to be consistently applied throughout the organization.
This policy covers all data collected by Caboodle Media Ltd. Co. and stored on Caboodle Media Ltd. Co. owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).
Reasons for Data Retention
Caboodle Media Ltd. Co. retains only that data that is necessary to effectively conduct its program activities, fulfill its mission and comply with applicable laws and regulations.
Reasons for Data Retention Include:
- Providing an ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing program updates to an individual, ongoing training or participation in Caboodle Media Ltd. Co.’s programs, processing of employee payroll and other benefits)
- Compliance with applicable laws and regulations associated with financial and programmatic reporting by Caboodle Media Ltd. Co. to its funding agencies and other donors
- Compliance with applicable labor, tax and immigration laws
- Other regulatory requirements
- Security incident or other investigation
- Intellectual property preservation
Caboodle Media Ltd. Co. seeks to avoid duplication in data storage whenever possible, though there may be instances in which for programmatic or other business reasons it is necessary for data to be held in more than one place. This policy applies to all data in Caboodle Media Ltd. Co.’s possession, including duplicate copies of data.
- Website visitor data will be retained as long as necessary to provide the service requested/initiated through the Caboodle Media Ltd. Co. website.
- Contributor data will be retained for the year in which the individual has contributed and then for three months after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.
- Event participant data will be retained for the period of the event, including any follow up activities, such as the distribution of reports, plus a period of three months;
- Program participant data (including sign in sheets) will be retained for the duration of the grant agreement that financed the program plus any additional time required under the terms of the grant agreement.
- Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.
- Employee data will be held for the duration of employment and then three months after the last day of employment.
- Data associated with employee wages, leave and pension shall be held for the period of employment plus three months, with the exception of pension eligibility and retirement beneficiary data which shall be kept for three months.
- Recruitment data, including interview notes of unsuccessful applicants, will be held for three months after the closing of the position recruitment process.
- Consultant (both paid and pro bono) data will be held for the duration of the consulting contract plus three months after the end of the consultancy.
- Board member data will be held for the duration of service on the Board plus for three months after the end of the member’s term. • Data associated with tax payments (including payroll, corporate and VAT) will be held for three months.
- Operational data related to program proposals, reporting and program management will be held for the period required by the Caboodle Media Ltd. Co. donor, but not more than three months.
Data destruction ensures that Caboodle Media Ltd. Co. manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, Caboodle Media Ltd. Co. will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to his/her supervisor and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by Caboodle Media Ltd. Co.’s data protection offer in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.
Compliance With Laws
We will disclose your Personal Information where required to do so by law or subpoena.