Contributor Privacy Policy

Effective as of October 1, 2022.

This “Privacy Policy” describes the privacy practices of Nota, Inc. and our subsidiaries and affiliates (collectively, “Nota”, “we”, “us”, or “our”) in connection with any pitch you submit to write a story for us.

We invite you to read this Privacy Policy, which explains our privacy practices and how we treat your personal information when you submit a pitch to write a story for us. It describes the types of personal information collected in connection with your submission of a pitch, how and why we use such information, who we share it with, and your legal rights. Certain portions of this Policy apply only to contributors located in certain jurisdictions.

Please consult our website privacy statement available here to obtain more information about our privacy practices related to your use of our website.

Personal Information We Collect

When you submit a pitch to write a story for us using our pitch form available on our website, you will provide us with:

Your name or alias;
Email address;
Country of residence;
Age range;
Profession;
The pronouns that would like to be addressed with.

You may also decide to provide us with sensitive information, such as information about your political beliefs, mental health, sexual orientation, ethnic or racial origin, religious or philosophical beliefs. Sensitive information will only be collected with your consent and will only be used in accordance with this privacy policy.

When you submit a pitch to write a story for us chatting with us on Keybase, although this platform is meant to protect your anonymity, you may decide to share with us some personal information about yourself.
When you submit a pitch to write a story for us by interacting with us on social media platforms, such as Facebook, LinkedIn, Twitter, Instagram, and other third party platforms, you may share with us your social media account details, such as your name, profile, photos, etc. The platform provider’s privacy policy applies to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
When we go after a story and identify you as a potential contributor, we may receive personal information about you from third-party sources, such as your contact details to enable us to get in touch with you.
When we determine that your narrative is a good fit, we will conduct due diligence to verify the authenticity of your identity and story. In this context, we will ask you to provide us with any information that you deem relevant to corroborate your identity and story, which may include:
- A link to your social media account profile (such as a link to your LinkedIn profile, etc.);
- A proof of your work occupancy (such as an email from your work email address; a picture of your business card; a picture of your work badge, etc.)
- A proof of your identity that only contains the information that we are allowed to process;
- A proof of residence;
- The contact details of a relative or friend who could back up your story provided that this person has authorized you to provide us with his/her contact details; etc.
  
  Please only provide us with information that is necessary and relevant for us to verify the authenticity of your identity and story.
When we decide to publish your story, we will ask you to provide us with your bank account details and tax information to be able to compensate you.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To register and process your pitch.

We use your personal information to assess whether your pitch is compelling enough to be published, if it is not similar to a story that we have already published or that has already been published elsewhere, whether it meets our editorial line, etc.

We further process your personal information to provide you with feedback on whether we have decided to select your pitch or not.

To verify the authenticity of your identity and story.

We use your personal information to conduct background searches to verify the ownership of your story and its reliability as described in the “When we determine that your narrative is a good fit, we will conduct due diligence to verify the authenticity of your identity and story” section above.

To ensure balanced and inclusive editorial curation.

We use your personal information, such information about your profession, age range, political beliefs if you decide to provide that information to us, etc. to ensure that our editorial curation is balanced and inclusive.

To provide our users with some background information in order to enable them to identify potential bias.

While your story will be published anonymously, we use your personal information to provide our users with some background information about you, such as your alias, your profession and your political beliefs if you decide to provide that information to us, etc.. Such background information enables our users to identify potential bias that you may have and to inform their reading of your story.

To compensate you for your published story.

We use your personal information to financially compensate you when we decide to publish your story.

To send you updates about our upcoming editorial needs.

With your consent where required by applicable laws, we may send you updates about our upcoming issues, the stories that we are looking for, etc. You will have the ability to opt-out of our communications at any time as described in the opt-out section below.

For compliance, fraud prevention, and safety purposes.

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the Terms of Use that govern the Site; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

To comply with law.

We use your 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.

With your consent.

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

How We Share Your Personal Information

We will always make sure that your anonymity is preserved. However, to be able to assess whether your story would be a good fit and to able to publish it, we may need to share your personal information with the following recipients which will process your personal information for the purposes described in this Privacy Policy:

Affiliates.

We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.

We may share your personal information with third party companies and individuals that provide services on our behalf or help us provide our services (such as hosting, email delivery, marketing, database management services, accounting services, and payment service). Our service providers include notably Docusign, Paypal, Clearstone Group, bill.com, etc. These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Third parties.

We may share your personal information with third parties to corroborate your identity and story. These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors.

We may disclose your personal information to professional advisors, such as accountants, lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others for compliance, fraud prevention and safety.

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transferees.

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Other users.

We may display your alias and other information which you select (e.g. generation, political affiliation, occupation) on articles contributors publish. Depending on what you choose as your alias and include in those self-selections, some of this information could constitute personal information in the categories described above.

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information.

If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt-out of contributor update communications.

You may opt out of contributor update emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [email protected] You may continue to receive service-related and other non-marketing emails.

Choosing not to share your personal information.

Please note that we may not be able to assess your pitch or publish your story if you choose not to share with us your personal information.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

European Union users should read the important information provided below about transfer of personal information outside of the European Union.

Children

Please note that you must not share with us personal information or submit a pitch to write a story for us if you are under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us at [email protected]

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. We may, and if required by law, will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Site.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting).

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to [email protected] You may also write to us via postal mail at:

Nota, Inc.

Attn: Legal – Privacy

5318 E. 2nd Street, PMB 42540, Long Beach, California 90803

California Privacy Notice

This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
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Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-in. If we know that you are under the age of 16, we will ask for your affirmative authorization to sell your Personal Information before we do so.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion at our webform or via email to [email protected]

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Personal Information that we collect, use and disclose. The list below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the list below, we disclose Personal Information as described in the How we share your Personal Informationsection above.

We do not sell personal information contributors provide to us and have not sold it during the 12 months preceding the effective date of this Privacy Policy.

Identifiers:

Categories: Name or alias, Email address, Postal address, Social media account information, Information in your communications with us
Sources: You, Third-party sources
Purposes: Register and process your pitch; Verify the authenticity of your identity and story; Ensure balanced and inclusive editorial curation; Provide users with background information to enable them to identify potential bias; Compensate you for your published story; Send you updates about our upcoming editorial needs; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Third parties; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees; Other users (as described above)

California Customer Records (as defined in California Civil Code §1798.80):

Categories: Name or alias, Email address, Postal address, Social media account information, Information in your communications with us, Bank account details and tax information, information about our history of payments to you, Information that you provide in your story or that we obtain in the process of verifying your story, Images or audio you submit to us.
Sources: You, Third-party sources
Purposes: Register and process your pitch; Verify the authenticity of your identity and story; ensure balanced and inclusive editorial curation; Provide users with background information to enable them to identify potential bias; Compensate you for your published story; Send you updates about our upcoming editorial needs; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Third parties; Professional advisors; Authorities and others for compliance, fraud prevention and safety; Business transferees; Other users (as described above)

Financial Information:

Categories: Bank account details and tax information
Sources: You
Purposes: Compensate you for your published story; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Professional advisors; Business transferees

Professional or Employment Information:

Categories: Information about your employment
Sources: You, Third-Party sources
Purposes: Verify the authenticity of your identity and story; Ensure balanced and inclusive editorial curation; Provide users with background information to enable them to identify potential bias; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Third Parties; Service providers; Professional advisors; Business transferees

Commercial Information:

Categories: Information about our history of payments to you
Sources: You, Third-party sources
Purposes: Compensate you for your published story; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Third parties; Service Providers; Professional advisors; Business transferees

Inferences:

May be derived from: Information that you provide in your story or that we obtain in the process of verifying your story, Images or audio you submit to us
Purposes: Register and process your pitch; Verify the authenticity of your identity and story; Ensure balanced and inclusive editorial curation; Provide users with background information to enable them to identify potential bias; Compensate you for your published story; Send you updates about our upcoming editorial needs; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Third parties; Service Providers; Professional advisors; Business transferees

Protected Classification Characteristics:

Categories: Information that you choose to provide to us, or which we learn in the process of verifying your story, which could include age, gender, sexual orientation, race or national origin, religious beliefs; Some protected classification characteristics may be inferable based on the content you provide even if you do not specifically disclose it
Sources: You, Third-party sources
Purposes: Register and process your pitch; Verify the authenticity of your identity and story; Ensure balanced and inclusive editorial curation; Provide users with background information to enable them to identify potential bias; Send you updates about our upcoming editorial needs; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Third parties; Service Providers, Professional advisors; Business transferees; Other users (to the extent you self-select to share this information with your article)

Sensory Information:

Categories: Images, including profile pictures and other images you upload to the site or provide in communications to us; audio you submit to us, such as when we transcribe your story
Sources: You
Purposes: Register and process your pitch; Verify the authenticity of your identity and story; Ensure balanced and inclusive editorial curation; Send you updates about our upcoming editorial needs; Compliance, fraud prevention, and safety; Comply with law
Third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Professional advisors; Business transferees

Shine the Light. Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at [email protected] or physical mail at 5318 E. 2nd Street, PMB 42540, Long Beach, California 90803. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Notice to Users Located in the EU and the UK

The information provided in this “Notice to Users located in the EU and the UK” section applies only to individuals located in the European Union or in the United Kingdom.

Personal information.

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by EU and UK data protection legislations.

Controller.

Nota, Inc. is the controller of your personal information covered by this Privacy Policy for purposes of EU and UK data protection legislations.

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, Nota, Inc. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Nota, Inc. has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

-by using EDPO’s online request form: https://edpo.com/gdpr-data-request/

-by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Legal bases for processing.

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.

Performance of a contract
We process your personal information as necessary to take steps prior to entering into a contract with you or to perform the contract that we have with you.
Legitimate Interests
We may process your information where it is necessary for the purposes of our legitimate interests. In particular, we process your information in furtherance of the following legitimate interests:
- To provide, improve, and develop our services: We use your information to provide our products and services to our users, including any personalized services, and to understand and improve our business. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our users and members on a sustained basis.
- To ensure the authenticity of your identity and story.
- To ensure that we have a balanced and inclusive editorial curation.
- To Keep the Services safe and secure: We use your information because it is necessary to pursue our legitimate interests or third party’s interest in protecting against fraud, spam and abuse, and enforcing our Terms of Use.
Your Consent
We will send you communications about our editorial needs where you have consented to receiving such communications in accordance with applicable law.
When you submit a pitch to us, we may process sensitive personal information about you, such as information about your political beliefs, mental health, sexual orientation, ethnic or racial origin, religious or philosophical beliefs. We will only process such sensitive personal information when you have explicitly consented to it and will only use it to ensure that our editorial curation is balanced and inclusive, and to enable our readers to identify potential bias that you may have.
Legal Obligation
We may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
- We may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and
- We may retain and process your information where it is necessary for compliance with applicable laws.

As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights

EU and UK data protection legislations give you certain rights regarding your personal information. If you are located within the European Union or the United Kingdom, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Withdraw consent. Where we are relying on your consent for the processing of your personal information, you have the right to withdraw your consent at any time.

You may submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator :

For the EU here
For the UK here

Cross-Border Data Transfer

If we transfer your personal information outside of respectively the European Union or the United Kingdom to a country not deemed by the European Commission or the UK Government (as and where applicable) to provide an adequate level of personal information protection, we will either:

Enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or
Rely on other appropriate means permitted by GDPR Ch. V, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.