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Privacy Policy

Adoptee Hub Inc.

Effective Date: March 3, 2021

Adoptee Hub respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Website, you agree to the terms and conditions of this Privacy Policy, which is incorporated into the Terms of Use, and to Adoptee Hub’s collection, use, and disclosure of your information in accordance with this Privacy Policy, where such agreement is permitted by applicable law.

This privacy policy describes how Adoptee Hub Inc. collects, uses, and discloses information from and about members when visiting and using www.adopteehub.org (the “Website”) and membership portal, and the ability to control certain uses of information.

We regularly review our compliance with this Privacy Policy. Whenever we receive a formal complaint, we make best efforts to contact the person who made the complaint to attempt to resolve their concerns. If you have any questions about the use of your information, or the contents of this Privacy Policy, please contact us: info@adopteehub.org.

Quick Guide to Contents

  • Privacy Policy 1
  • Quick Guide to Contents 1
  • Collection of Information 1
  • How We Use Your Information 3
  • How We Disclose Your Information 5
  • Information Security and Data Retention 6
  • Accessing and Managing Your Personal Information 6
  • Additional Information 7

Collection of Information

Information You Provide

Adoptee Hub collects information from you when you choose to provide it to us. For example, we collect your information when you submit a webform requesting information about Adoptee Hub-post adoption programs (the “Program”), or otherwise contact us or provide information to us through the Website. The information we collect includes personal information – such as your name, address, email address, telephone number, prior educational background information, work experience, and the content of any communications that we exchange, as well as non-personal information.

For those individuals that choose to start an Adoptee Hub program application, we collect personal information required to conduct appropriate and quality services.

In some cases, we require your personal information to perform a contract or to comply with a legal obligation.

Information Automatically Collected

When you visit the Website or interact with emails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our third-party partners use cookies and other technologies to collect information about your visit to the Website, such as the date and time of your visit, the information you searched to find the Website, your activity on the Website, and your clicks on our ads. “Cookies” are small files which may be stored on your computer during your use of the Website and contain data about your use of the Website. We use session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or after a specified expiry date) to understand more about your activity on the Website.

Tracking Options and Do Not Track Disclosures

You may adjust your browser or operating system settings to limit tracking or to decline cookies. If you choose to limit tracking or decline cookies, however, you may be unable to access certain areas of the Website. Check the “Help” or “Settings” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. On your mobile device, you can adjust your privacy and advertising settings to limit tracking for advertising or to control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

Information Collected from Other Sources

Where permitted by law, we collect or receive information about you from other organizations to whom you indicate that you would like us to use in order to provide appropriate post-adoption services or other entities within the Adoptee Hub staff partners and affiliates (collectively “Other Sources”) in order to update or supplement the information that you provide or that we collect automatically. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can conduct proper post-adoption services or provide other information that may be of interest to you, and for internal business analysis or other business purposes.

Our Combination of Your Information

We combine the information we receive from and about you via the Website and from other sources to help us tailor our communications to you and to improve the Website.

Failure to Provide Personal Information

Failure to provide certain information may make it difficult or impossible for you to receive and access our services through the Website or in person (for example, to apply for our service programs). You should ensure that personal information submitted to us is accurate and current. For example, we always need a current email address, mailing address, and phone number to communicate with you about the program services to which you are applying to.

Children’s Privacy

We do not direct the Website to, nor do we knowingly collect any personal information from, children under the age of 18.

How We Use Your Information

Purposes for Collecting and Processing Personal Information

We process personal information under the following legal basis:

  • To fulfill a contract or take steps linked to a contract, including providing our services and communicating with you.
  • To conduct Adoptee Hub’s business and services; pursue our legitimate interests in marketing our business; ensuring that we conduct our business upholding our mission; improving and developing our programs and services; and keeping our records accurate and up to date. This includes the following:
    • Using your information to provide information and services you have requested and responding to any comments or complaints you may send us.
    • Personalizing your experience on the Website and helping us to better respond to your individual needs.
    • Targeting advertising to groups of individuals with similar interests or characteristics through services offered by third party Service Providers, such as Facebook Custom Audiences or other similar business tools.
    • Developing new products or services or conducting analyses to enhance current products and services.
    • Reviewing the usage and operations of the Website and analyzing and improving the Website. (We continually strive to improve the Website based on the information and feedback we receive from you.)
    • Contacting you for legitimate business purposes as authorized.
    • Using contact information to invite individuals to take part in various relevant opportunities.
    • Where consent is not required by applicable law, for direct marketing purposes.
    • Protecting the security and functionality of the Website, including using personal information you provide to investigate any complaints received from you or from others about our Website or our products and services.

Where you give us consent. This includes the following:

  • Where consent is required by applicable law, sending you direct marketing in relation to our relevant information and post-adoption services, or other products and services provided by Adoptee Hub.
  • On other occasions where we ask you for consent, using the data for the purpose which we explain at that time.

For purposes which are required by law. This includes the following:

  • In response to requests by government or law enforcement authorities conducting an investigation.
  • Using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.

For reasons not described in this Privacy Policy where the reason is compatible with the purpose for which we originally collected your information and where such use is lawful.

Processing Information at your request of our post-adoption services.

Adoptee Hub collects and processes your personal information when you choose to apply for Adoptee Hub’s program services. This processing of your personal information is conducted at your request of performing services.

  • Providing our services, such as the following:
    • Processing application materials and fees
    • Contacting members to provide support during the application process.
    • Setting up and managing accounts and profiles.
    • Verifying your identity through a passport, Real ID, or Military ID.
    • Taking payments.
  • Protecting the security and functionality of the Website, including the following:
    • If you provide a credit or debit card as payment, using third parties (Square) to check the validity of the sort code or routing number, account number and card number you submit in order to prevent fraud; and
    • Monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law.

Use of De-identified, Aggregate, or Anonymized Information

We use de-identified, aggregate, or anonymized information to help us analyze the use of the Website. Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate, pseudonymous, or anonymous information. We reserve the right to use and disclose such information to our partners, advertisers, and other third parties in our discretion (no third party sharing).

How We Disclose Your Information

Adoptee Hub shares your information with other entities or individuals in the following limited circumstances:

  1. Adoptee Hub staff and contractors, and other related parties: Where you have expressed interest and given your consent, we share your information within Adoptee Hub’s professionals to provide you with information about other educational programs.
  2. Service Providers: We share your information with third parties that provide business, professional, or technical support functions for us. We use third-party providers for website hosting, maintenance, marketing services, courier services, certification services, social service services to support or post adoption services, business operations, payment services, and identity verification services (“Service Providers”). These Service Providers are only given access to your information to the extent necessary to process your information and/or provide services to Adoptee Hub, and they are prohibited from using or sharing your information for any other purposes. Where permitted by law, Adoptee Hub discloses limited information about you to service providers to serve relevant advertising on third party platforms to you or to other audiences.
  3. Legal Matters/Safety: We access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We disclose your information to protect the security of Adoptee Hub’s services, the Website, servers, network systems, and databases. We also disclose your information, as necessary, if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Website, or the rights of any third party.
  4. Fraud/Security: We access and disclose your information to detect, prevent, or otherwise address fraud, security, or other technical issues.
  5. Consent/Other: We share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
  6. Sale or Transfer of Business or Assets: In the event of a merger or acquisition, Adoptee Hub reserves the right to transfer assets during the normal course of our business. If another organization acquires us or any of our assets, information we have collected about you may be transferred to such organization. Should such a merger or transfer occur, you will be notified for consent and we will use reasonable efforts to try to require that the transferee use your information in a manner that is consistent with this Privacy Policy.
  7. International Transfers: We transfer personal information from The Republic of South Korea (ROK); the European Economic Area (“EEA”) to other countries, including the United States and Canada, where post-adoption information is transferred outside the EEA to a third party in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by Standard Contractual Clauses, and an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules applies. A copy of the relevant mechanism can be provided for your review on request to: info@adopteehub.org.

Information Security and Data Retention

We are committed to protecting the security of your information. We maintain what we believe to be appropriate physical, electronic, and managerial procedures to safeguard and secure your information and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your information. The accuracy, safety, and security of your information also depends on you. Where we have given you—or where you have chosen—a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, the transmission of information via the Internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information if you chose to apply with other post-adoption services outside of Adoptee Hub. We retain your personal information for as long as we have a relationship with you. We will also retain your personal information for a longer period, which enables us to do the following:

  • Maintain business records for analysis and/or audit purposes.
  • Comply with record retention requirements under the law.
  • Defend or bring any existing or potential legal claims.
  • Address any complaints regarding the services.
  • Enforce our commercial agreements.
  • Support our legitimate interests, as described in this Privacy Policy.

HIPPA Compliance

Disclaimer: This is addressed in more detail in a separate document. For further details, please ask the Adoptee Hub copywriter group for this document.

Accessing and Managing Your Personal Information

If you have completed one of Adoptee Hub’s applications online or in a hard copy, you may access and/or update your personal information through your user profile.

In some instances, you may be eligible to (a) ask us for a copy of your personal information; (b) correct or restrict processing of your personal information; and/or (c) obtain the personal information you provide to us in a structured, machine-readable format. In addition, you may have the right under applicable law to object to the processing of your personal information in some circumstances.

Your rights regarding your personal information may be limited, for example, if fulfilling your request would reveal personal information about another person or would infringe on the rights of a third party (including our rights). We will inform you of the relevant exemption upon which we rely when responding to any request you make.

Our use of certain personal information is necessary for us to provide information to you about post-adoption services to you through the Website, the Adoptee Hub Portal or any Adoptee Hub communications. If you choose not to provide this personal information or request that Adoptee Hub may restrict the processing of this personal information, you may not be able to participate in the Program, and we may not be able to provide you with other services, including those provided through the Website or advertised on our program services.

You always have the right to opt out of our organization and services by cancelling your membership. We will regardless maintain your information unless you have in writing expressed your desire to have all records deleted.

If you believe your rights regarding your personal information have been infringed upon, please contact us. If you are in the EEA or Switzerland and have unresolved concerns, you also have a right to lodge a complaint with the applicable Data Protection Authority.

If you wish to access or delete your information as described in this section, please contact us at: info@adopteehub.org.

Additional Information

Public Forums; Publicly Available Content

Any information you may disclose through the Website and Portal, such as on message boards, in chatrooms, or in other public areas, such as on webinars that you may attend about the Program, may be viewed by others, such as your classmates and learning facilitators. Please exercise caution when disclosing personal information in these public areas. If you do not want Adoptee Hub to store metadata associated with your content, please remove the metadata before uploading your content.

Third-Party Content

The Website may also offer you the ability to interact with content provided by third parties not affiliated with Adoptee Hub (“Third-Party Content”). Third-Party Content linked to or embedded on this Website is governed by the privacy policies of those third parties. Your use of Third-Party Content is subject to each site’s privacy policy, which may be different from ours. We have no control over the information that is collected, stored, or used by Third Party Content.

Changes to this Privacy Policy

We review this Privacy Policy quarterly and reserve the right to make changes to this Privacy Policy at any time. If we do make material changes, we will give public notice via the Website features or by contacting you via email.

Questions or Concerns About this Privacy Policy

You may direct any questions or concerns regarding this Privacy Policy to us at: info@adopteehub.org.