Privacy Policy

Effective Date: March 20, 2019

 

Contents

1.      Information We May Collect About You

     1.1.       Through Metro Services

     1.2.       From Other Sources

     1.3.       Information Automatically Collected from Your Use of Our Services

          1.3.1.         Device Information and Location-Based Information

          1.3.2.         Cookies

          1.3.3.         Analytics, Log Files and Reading History

2.      How Will We Use and Share Personal Information About You?

     2.1.       We May Use (Process) That Personal Information and Provide Our Legal Basis for Doing So

     2.2.       We May Share That Information

3.      Third-Party Advertising

4.      International Transfers

5.      Keeping Your Personal Information Secure

6.      Retention of Your Personal Information

7.      What Rights Do You Have?

     7.1.       EU-Based Users

          7.1.1.         Right of Access to Your Information

          7.1.2.         Right to Correct Any Mistakes in Your Personal Information

          7.1.3.         Right to Erasure

          7.1.4.         Right to Restrict Processing of Your Personal Information

          7.1.5.         Right to Data Portability

          7.1.6.         Right to Object

          7.1.7.         Right to Withdraw Consent

     7.2.       California Residents

8.      Use of The Services by Children

9.      Changes to This Privacy Policy

10.    Complaints

11.    Questions on Privacy and How to Contact Us

 

26June1945, LLC (‘’Metro – Views on issues at the United Nations,’’ “Metro,” “we,” “our,” or “us”) recognizes the importance of your privacy and the security of your personal information. We want you to be familiar with how we collect, use and disclose them.

The following Privacy Policy applies only governs the use and disclosure of user personal information in conjunction with your use of the Metro – Views on issues at the United Nationswebsite (currently located at www.metro-un.com)and our mobile or tablet application, interactive services, email newsletter and mobile device (collectively referred to as the “Services”), provided by Metro or our potential affiliates or licensees and that display an authorized link to this policy. The Services do not include Metro newspaper. The following Privacy Policy does not govern or apply to information collected or used by us through other means, nor does it apply to our other websites (including those of parent or sister companies) or websites for which potential links are contained in our Services, that display a different Privacy Policy. Our Services may contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of those sites.

 Please read the sections below carefully to know and accept how this Privacy Policy applies to your use of our Services.

1. Information We May Collect About You

When you use Metro services, we gather personal information about you. Personal information is information that we directly associate with a specific person, or that can reasonably be used to identify a specific person such as a name, address, telephone number, email address, or Internet Protocol (IP) address.

1.1. Through Metro Services

Metro may collect and store personal information such as your name, email, job title, organization, nationality, phone number, payment information, date of birth, gender, street address or otherwise, that you voluntarily supply either while on the website or in responding, via email or other method to a feature published on the website.

We may collect payment information, such as your credit card number, billing address and expiration date, where appropriate to process a financial transaction you have requested.

Metro does not collect or process sensitive personal data related to race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health or mortality, or sex life or sexual orientation.

1.2. From Other Sources

If you choose to link your social media account to Metro, you may be asking third parties to share with us certain information from those social media accounts, and you are authorizing us to collect, store, and use what they send us in accordance with this Privacy Policy. You can dissociate your Metro registration from third-party accounts any time.

1.3. Information Automatically Collected from Your Use of Our Services

Metro also collects and stores through technology information that is generated automatically as you navigate through the website.  This collected information does not specifically identify you. It includes tracking information collected by us as well as third parties.

We use various internet technologies to manage, and track the use of our Services. We use and disclose this information for any purpose, except where we are required to do otherwise under applicable law. Information that we collect using these technologies is combined with personal information about you. If we combine information with personal information, we will treat the combined information as personal information.

   1.3.1. Device Information and Location-Based Information

We may collect certain information about the computer or devices (including mobile devices) you use to access Metro services, such as IP addresses, unique device identifiers, browser type, browser language and other transactional information.

Certain mobile devices, including smartphones and tablet devices, contain unique device IDs that can be used to identify their physical location. Mobile devices also typically transmit caller ID data (which may include a phone number) when used to transmit a telephone call or text message. When you use mobile devices to access our Services, Metro may collect and transmit unique device IDs and collect caller ID data, information about your wireless carrier, the make, model and operating system of your device and information about how you navigate within the website.

Another type of information that we automatically collect as you navigate the website is information collected about the location of a mobile device or computer. This information allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on our website.

   1.3.2. Cookies

To enhance your experience on the website, we use a standard feature found in browser software called a “cookie.” Cookies are small files that your web browser places on your hard drive for record-keeping purposes that allows the Metro website to distinguish you from others. By showing how and when visitors use the website, cookies help us track user trends and patterns and to show users the most relevant material available on the services. Cookies also may save you the trouble of having to re-enter your preferences on certain areas of the website where you may have made a selection or preference before.

There are several types of cookies that may be used on a website: 

  • First Party Cookies: cookies that are set by the web server of the visited page and share the same domain.
  • Third Party Cookies: cookies that are set by a domain other than the website a user is currently visiting.
  • Persistent Cookies: cookies that are added when a visitor starts to browse a website or interacts with a specific feature, but may remain stored on a browser or device until a certain termination date is reached.
  • Session Cookies: cookies that are added when a visitor starts to browse a website or interacts with a specific feature, and are deleted when the browser is closed.

 

 

Currently, we use cookies to remember your language preferences as well as your log-in information.

 

At any time, you may choose to block or enable cookies. Your browser can be set to notify you when you receive a cookie (allowing you to decide whether or not to accept it) or to reject all cookies. Each browser has its own way of giving you these options (for example, depending on whether you are using Microsoft Internet Explorer, Mozilla Firefox, Safari, Google Chrome or other browsers), so please consult your browser’s “help” menu for further details or visit the browser’s website and click on the relevant links (for instance, to delete or disable cookies when using Internet Explorer: https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-fil...). Please set up your web browser according to your expectations and requirements. We remind you that disabling or rejecting cookies may prevent you from using certain parts of our website.

For additional information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2.

   1.3.3. Analytics, Log Files and Reading History

As is commonly done with most websites, we log each visit to each of our website page. A log entry can contain information typically found in the "header" of your web browser's request such as the browser type you used, your Internet Protocol address, and the date and time of day. We may also log your session identifier and the URL of a site that referred you. This log information is important for security, audit, quality improvement, as well as for monitoring the health of our services.

The analytics service providers we use are Google Analytics and Parse.ly. To learn more about how Google uses data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. To learn more about how Parse.ly uses data and opt-out options specific to Parse.ly, visit https://www.parse.ly/privacy-policy/.

2. How Will We Use and Share Personal Information About You?

2.1. We May Use (Process) That Personal Information and Provide Our Legal Basis for Doing So

Metro collects, uses, and otherwise processes your personal information as allowed under applicable law, including where based on one or more of the following:

  • The consent you provide to us at the point of collection of your personal information;
  • The performance of a contract we have with you;
  • The compliance of a legal obligation to which we are subject; or
  • The legitimate interests of Metro or a third party, except where such interests are overridden by your interests of fundamental rights and freedoms. Metro has a legitimate interest in collecting and processing personal information, for example: (1) to administer and generally conduct business within Metro; and (2) to prevent fraud.

We use the information that we collect about you for the following purposes:

  • Provide the Services you request. This includes processing your subscription, processing and responding to your inquiries, arranging access to your registered account sending you administrative information, providing registration details, or otherwise interacting with our Services. The basis of this processing is to perform our contractual relationship with you or to comply with a legal obligation.
  • Customizing your experience. Metro uses your personal Information to better understand you and to provide you with personalized content and recommendations, including by email, as well as to enable you to participate in the features provided by the services. Metro engages in these activities because we have a legitimate interest.
  • Email Newsletter and Facilitating Social Sharing. Metro will use your personal Information to set up newsletter preferences and send you email newsletters or promotional emails about services offered by Metro. You may opt out of receiving commercial email messages from us by following the instructions contained in those email messages. If you experience difficulty with the “unsubscribe” process, please contact us at privacy@metro-un.net. If you choose to use social-sharing functionalities, we will use your information to facilitate such action, and such action will be covered by the social media platform’s Privacy Policy. Metro engages in these activities with your consent or where we have a legitimate interest.

2.2. We May Share That Information 

As part of our Services, we may share information with other entities. Our practices vary depending on the type of information.

Within Metro.We may share your personal information with our employees and consultants for the sole purpose of ensuring appropriate delivery of our Services and only if it is strictly necessary. Please note that as our business grows, we may buy or sell various assets. In the unlikely event that Metro, some or all of our assets, or our site is acquired by another company, information on our visitors may be among the transferred assets.

Service Providers.We may share information with companies providing contractual services to us, including but not limited to hosting, developer (for instance Stygasoft), e-mail services providers (for instance Dotmailer), e-reader (for instance PageSuite), analytics service providers (see below), potential advertising service providers. We also may share your information, including your payment information, as appropriate to process your payments for the Services or complete a transaction.These entities may have access to personal information if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the confidentiality and security of that personal information. They are restricted from using, distributing, or altering this data in any way other than to provide the requested services to us.

Other parties when required by law or as necessary to protect our Services. We may share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users or to comply with applicable law or legal process, including responding to requests from public and government authorities.

Marketing. Metro does not use the information that it collects online from you while you are using the services and we will not allow third parties to use such information for commercial purposes or to send promotional offers directly to you unless you have indicated that you would like to receive such promotional offers from us or third parties. If you do choose to receive these promotional offers, then your information may be used for direct mail or email marketing purposes.

Public Activity. Please remember that whenever you may disclose or publish personal information authorized by us, and it is therefore not possible for us to be responsible for any unauthorized collection or use of such information that you have chosen to disclose in the public domain.

3. Third-Party Advertising

Metro does not have any of its services or advertisements delivered or served by third-party companies.

4. International Transfers

Our Services are hosted in the United States and are governed by United States law. If you are using the services from outside the United States, please be aware that your personal information may be transferred to, stored and processed in the United States and other countries where our servers are located and our databases are operated. This transfer is necessary for the legitimate interests of Metro as it is necessary to administer and generally conduct business within Metro. The data protection and other laws of the United States and other countries may not be as comprehensive or protective of certain rights as those in your country. Under United States law, your personal information may be subject to access requests from governments, courts, or law enforcement in the United States. By using the services, you consent to your information being transferred to our facilities and to the facilities of those third parties described within this policy with whom we share it and processed in their facilities.

We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards.

While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy. Indeed, this Privacy Policy applies to individuals located in the European Union (“EU”) and the European Economic Area (“EEA”). If we transfer personal information outside the EU and EEA, we will implement appropriate and suitable safeguards to ensure that such data will be protected as required by applicable data protection law. For this purpose, please read carefully the relevant EU regulations: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=FR.

5. Keeping Your Personal Information Secure

We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at privacy@metro-un.net.

6. Retention of Your Personal Information

Except as otherwise permitted or required by applicable law or regulatory requirements, Metro will not retain your personal data longer than is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

To determine the appropriate retention periods, Metro takes into account:

  • How long Metro provides our Services to you (for instance, for as long as you are registered to our website or continue to use our Services);
  • The legal obligations to which we are subject (for instance, certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
  • According to legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).  

7. What Rights Do You Have?

If you would like to exercise one of the following rights regarding your personal information, please contact us at privacy@metro-un.net. For your protection, we only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

We will respond to your request consistent with applicable law.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

7.1. EU-Based Users

If the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), you have the following rights listed below. You can exercise these rights under the GDPR by contacting us at privacy@metro-un.net. Please put the statement “GDPR Privacy Rights” in the subject line of your request, and include your name, country or region, and enough information to allow us to respond to your request in the body of your e-mail. 

   7.1.1. Right of Access to Your Information

This right allows you to be aware of and verify the lawfulness of the process of collecting your information. Therefore, you have the right to obtain confirmation that your data is being processed access to your personal data and other additional information.

   7.1.2. Right to Correct Any Mistakes in Your Personal Information

You can require us to correct any mistakes in your personal data, which we hold about you, whether it is inaccurate or incomplete.

   7.1.3. Right to Erasure

You can require us to erase personal information we hold about you without undue delay in the following circumstances:

  • The personal data is no longer necessary in relation to the purpose for which it was originally collected/processed;
  • You withdraw consent on which the processing is based and there is no other legal ground for the processing of the data;
  • You object to the processing and there is no overriding legitimate interest for us to continue the processing of the data;
  • Your personal data was unlawfully processed; or
  • Your personal data must be erased in order to comply with a legal obligation.

We may not always be able to comply with your request of erasure for specific legal reasons, which will be provided to you, if applicable, at the time of the request.

   7.1.4. Right to Restrict Processing of Your Personal Information

You have the right to restrict the processing of your personal data in the following circumstances:

  • You contest the accuracy of the personal information;
  • You have objected to our processing of your personal information, and we are considering your objection because we have said the processing is necessary for the purposes of our legitimate interests;
  • The processing is unlawful and you do not wish for the data to be erased but require restricted processing of the personal information instead; or
  • We no longer need your personal information but you require the data to establish, exercise or defend a legal claim.

   7.1.5. Right to Data Portability

You have the right to obtain and reuse your personal data across different services for your own purposes. This right only applies:

  • To personal information you provided to us;
  • Where the processing is based on your consent or for the performance of a contract; and
  • When processing is automated.

   7.1.6. Right to Object

You have the right to object to us processing your personal information where our legal basis for doing so is:

  • Direct marketing (including profiling);
  • For the purposes of our legitimate interest; or
  • For scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

   7.1.7. Right to Withdraw Consent

Where we have relied on your consent for the processing of your personal data, you have the right to withdraw that consent at any time. If you wish to withdraw you consent please, email, call or write to us using the contact details under ‘How to contact us’ below.

7.2. California Residents

Under the California “Shine The Light” law, California residents may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. As detailed above, you may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request in writing to Metro – Views on issues at the United Nations, 120 Broadway, Suite 220, New York, NY 10271 or by emailing us at privacy@metro-un.net. It is important to note that this opt-out request does not prohibit us from sending you important administrative disclosures for non-marketing purposes. We will comply with your request(s) as soon as reasonably practicable.

8. Use of The Services by Children

   a. US-Based Children

Metro will not knowingly allow anyone under the age of 13 to provide us any personal information online. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally-identifiable information from a user under the age of thirteen as part of our Services, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Services. If you are under 13, please do not register for our Services and please do not provide us with any personal information (such as your name, postal or email address or phone number). If you are the parent or legal guardian and you believe we may have inadvertently collected personal information from a child under 13, please contact us to request the child's information be deleted by contacting us at privacy@metro-un.net.

   b. EU-Based Children

     Metro will not knowingly allow anyone under the age of 16 (or younger depending on relevant EU Member State law) to provide us any personal information online. We screen users who wish to provide personal information in order to prevent users under the age of 16 (or younger depending on relevant EU Member State law) from providing such information. If we become aware that we have inadvertently received personal information from a user under the age of 16 (or younger depending on relevant EU Member State law) as part of our Services, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of 16 (or younger depending on relevant EU Member State law) as part of the Services. If you are under 16 (or younger depending on relevant EU Member State law), please do not register for our Services and please do not provide us with any personally identifying information (such as your name, postal or email address or phone number). If you are the parent or legal guardian and you believe we may have inadvertently collected personal information from a child under 16 (or younger depending on relevant EU Member State law), please contact us to request the child's information be deleted by contacting us at privacy@metro-un.net.

9. Changes to This Privacy Policy

Metro reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology. Any changes we make to this Privacy Policy will be posted on this page. If we make a significant or material change in the way we use or share your personal information, you will be notified by a notice on the Metro website. The continued use of our Services means you will be deemed to have implicitly consented to any change and/or update that may have occurred to our Privacy Policy.

10. Complaints

We take your privacy very seriously and try to adhere to the highest standards when collecting and processing your data.  However, if you think there is a problem with the way we are processing your personal data, then we encourage you to contact us directly at privacy@metro-un.netto see if your concerns can be addressed. If you are not satisfied with the outcome of our internal complaint procedure, or if you consider that your complaint has not been handled correctly you may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.

A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

11. Questions on Privacy and How to Contact Us

Please contact us if you have any question about this Privacy Policy or the information we hold about you, including making requests to exercises any of your rights in relation to your personal data.

If you wish to contact us, please sent an email to privacy@metro-un.net or write to us at Metro – Views on issues at the United Nations, 120 Broadway, Suite 220, New York, NY 10271 or call us on (202) 352-6076.