Section 1: Data Collection
WiredScore will collect the following types of information (“User Content”) related to Users: Information provided by Users directly: By registering an account on the Wired Certification website or providing data to WiredScore via email, WiredScore asks for certain User Content such as the User’s first and last name, phone number, email address, building borough-block-lot numbers, rentable square footage, building name, username, and password. Users also provide detailed information about the broadband capabilities of their building though the Wired Certification survey assessment process, either online or via an excel tool. WiredScore uses this information to operate, maintain, and provide the features and functionality of the Wired Certification program.
We claim no ownership rights over User Content created by you. The User Content you create remains yours; however, by sharing User Content through the Service, you agree to allow others to view and/or share your User Content in accordance with your settings and this Policy. WiredScore has the right (but not the obligation) in its sole discretion to remove any User Content that is shared via the Service.
You agree not to post User Content that: (i) may create a risk of harm, loss, physical or mental injury, emotional distress, death, disability, disfigurement, or physical or mental illness to you, to any other person, or to any animal; (ii) may create a risk of any other loss or damage to any person or property; (iii) seeks to harm or exploit children by exposing them to inappropriate content, asking for personally identifiable details or otherwise; (iv) may constitute or contribute to a crime or tort; (v) contains any information or content that we deem to be unlawful, harmful, abusive, racially or ethnically offensive, defamatory, infringing, invasive of personal privacy or publicity rights, harassing, humiliating to other people (publicly or otherwise), libelous, threatening, profane, or otherwise objectionable; (vi) contains any information or content that is illegal (including, without limitation, the disclosure of insider information under securities law or of another party’s trade secrets); (vii) contains any information or content that you do not have a right to make available under any law or under contractual or fiduciary relationships; or (viii) contains any information or content that you know is not correct and current . You agree that any User Content that you post does not and will not violate third-party rights of any kind, including without limitation any Intellectual Property Rights (as defined below) or rights of privacy. WiredScore reserves the right, but is not obligated, to reject and/or remove any User Content that WiredScore believes, in its sole discretion, violates these provisions. You understand that publishing your User Content on the Service is not a substitute for registering it with the U.S. Copyright Office, the Writer’s Guild of America, or any other rights organization.
WiredScore takes no responsibility and assumes no liability for any User Content that you or any other User or third party posts or sends over the Service, or any action you take in reliance on any User Content posted by another User. You shall be solely responsible for your User Content and the consequences of posting or publishing it, and you agree that we are only acting as a passive conduit for your online distribution and publication of your User Content.
You understand and agree that you may be exposed to User Content that is inaccurate, objectionable, inappropriate for children, or otherwise unsuited to your purpose, and you agree that WiredScore shall not be liable for any damages you allege to incur as a result of User Content. Information provided to WiredScore is completely voluntary. You are always able to change the information you provided to us and make any desired changes to your profile settings and the information you display publicly on your profile. You can always:
- Review and change your information through your profile page
- Choose what information you decide to display publicly
- Close your account
Information WiredScore receives from the New York City government: WiredScore receives information from the New York City government and various city agencies such as the Department of Finance related to Users. This information is publicly accessible today and may likely include any of the public data on file in the Department of Finance Tax Assessment Roll database related to the Users’ buildings, including year built, number of floors, square footage, address, and other basic building information. Any inaccuracies the User finds in the data provided by the NYC Department of Finance or other third parties should be corrected by contacting those 3rd parties directly.
Section 2: Sharing Of Users’ Information
WiredScore will not share a User’s information with third parties without the User’s consent, except as noted below: Who the User agrees to share information with: Any information or content that the User voluntarily discloses for posting to the Wired Certification website through acceptance of this Policy, such as survey data or information on a building’s profile page on the Wired Certification website, becomes available to the public to be searched for and viewed. The User can change privacy settings by contacting the Wired Certification Administrators at firstname.lastname@example.org or changing settings directly on the Wired Certification website by adjusting account settings. If the User removes information previously posted to the website, copies may remain viewable in cached and archived pages of the website, or if other users have copied or saved that information. Information collected through the Wired Certification initiative will be provided in Application Programming Interface (“API”) format to the New York City Economic Development Corporation (“NYCEDC”). The NYCEDC retains the right to make this information available to the public and accessible through various New York City government websites, pursuant to NYC Open Data legislation – Local Law 11 of 2012 and the Department of Information Technology and Telecommunications (“DoITT”) Open Data Policy and Tech Standards.
We may share aggregated information about our Users with advertisers (eg. general demographic information like age range, location, profession). We do not share personally identifiable information with third party advertisers. We share information with third party service providers to allow them to perform their services. This is to carry out functions like performing payment processing and conducting quality assurance.
If you give us permission, we may share some personally identifiable information, such as an email address or phone number with businesses who we think can offer you useful services. What happens in the event of a change of control: In the event of a change of control of the Wired Certification Initiative, the User’s information such as survey responses and building profile information may be transferred to a new managing entity.
Instances where WiredScore is required to share the User’s information: WiredScore will disclose the User’s information where required to do so by law or subpoena or if WiredScore reasonably believes that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of WiredScore’s service; and/or (c) to exercise or protect the rights, property, or personal safety of WiredScore, WiredScore’s users or others.
Keeping the User’s information safe: WiredScore cares about the security of the User’s information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through Wired Certification. To protect the User’s privacy and security, WiredScore utilizes a two-stage registration process (it includes both requesting a unique password and sending an identity validation email to the User’s account) to verify the User’s identity before granting account access. The User is responsible for maintaining the secrecy of the unique password and account information, and for controlling access to email communications from WiredScore, at all times. However, WiredScore cannot ensure or warrant the security of any information the User transmits to WiredScore or guarantee that information on the service may not be accessed, disclosed, altered, or destroyed. WiredScore is not responsible for the functionality or security measures of any third party.
Compromise of information: In the event that any information under WiredScore’s control is compromised as a result of a breach of security, WiredScore will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Control of account information and settings: Users may update their account and survey info at any time by logging in to their account and changing the data reflected. If the User has any questions about reviewing or modifying information, WiredScore can be contacted directly at email@example.com.
Section 3: Consent
How do you get my consent?
When you provide us with User Content as part of our Service, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdrawing your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by changing your account profile settings or contacting us at info@wiredscore.
Section 5: Questions And Contact Information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at firstname.lastname@example.org .
Section 6: DMCA Policy
WiredScore has adopted the following general policy toward copyright infringement in accordance with the Digital Millennium Copyright Act . The address of the Designated Agent to Receive Notification of Claimed Infringement (“Designated Agent”) is listed at the end of this policy. Procedure for Reporting Copyright Infringement:
If you believe that material or content residing on or accessible through WiredScore’s websites or services infringes a copyright, please send a notice of copyright infringement containing the following information to the Designated Agent listed below:
- A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright that has been allegedly infringed;
- Identification of works or materials being infringed;
- Identification of the material that is claimed to be infringing including information regarding the location of the infringing materials that the copyright owner seeks to have removed, with sufficient detail so that Fathom is capable of finding and verifying its existence;
- Contact information about the notifier including address, telephone number and, if available, e-mail address;
- A statement that the notifier has a good faith belief that the material is not authorized by the copyright owner, its agent, or the law; and
- A statement made under penalty of perjury that the information provided is accurate and the notifying party is authorized to make the complaint on behalf of the copyright owner.
Please contact the Designated Agent to Receive Notification of Claimed Infringement for Company at email@example.com .
WiredScore GDPR Policy
WiredScore is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct.
This policy sets forth the expected behaviours of WiredScore Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a WiredScore Contact (i.e. the Data Subject).
Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data. An organisation that handles Personal Data and makes decisions about its use is known as a Data Controller. WiredScore, as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy. Non-compliance may expose WiredScore to complaints, regulatory action, fines and/or reputational damage.
WiredScore’s leadership is fully committed to ensuring continued and effective implementation of this policy, and expects all WiredScore Employees and Third Parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction. This policy has been approved by Arie Barendrecht, WiredScore CEO.
This policy applies to all WiredScore Entities where a Data Subject’s Personal Data is processed:
- In the context of the business activities of the WiredScore Entity.
- For the provision or offer of goods or services to individuals (including those provided or offered free-of-charge) by a WiredScore Entity.
- To actively monitor the behaviour of individuals.
- Monitoring the behaviour of individuals includes using data processing techniques such as persistent web browser cookies or dynamic IP address tracking to profile an individual with a view to:
o Taking a decision about them.
o Analysing or predicting their personal preferences , behaviours and attitudes.
This policy applies to all Processing of Personal Data in electronic form (including electronic mail and documents created with word processing software) or where it is held in manual files that are structured in a way that allows ready access to information about individuals. This policy has been designed to establish a worldwide baseline standard for the Processing and protection of Personal Data by all WiredScore Entities. Where national law imposes a requirement which is stricter than imposed by this policy, the requirements in national law must be followed. Furthermore, where national law imposes a requirement that is not addressed in this policy, the relevant national law must be adhered to. If there are conflicting requirements in this policy and national law, please consult with our DPO (Sanj) for guidance. The protection of Personal Data belonging to WiredScore Employees is not within the scope of this policy. [It is covered in the WiredScore ‘Data Protection for Employee Data’ policy.]
The management team of each WiredScore Entity must ensure that all WiredScore Employees responsible for the Processing of Personal Data are aware of and comply with the contents of this policy. In addition, each WiredScore Entity will make sure all Third Parties engaged to Process Personal Data on their behalf (i.e. their Data Processors) are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all Third Parties, whether companies or individuals, prior to granting them access to Personal Data controlled by WiredScore.
Data Protection Principles
WiredScore has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data:
Principle 1: Lawfulness, Fairness and Transparency
Personal Data shall be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. This means, WiredScore must tell the Data Subject what Processing will occur (transparency), the Processing must match the description given to the Data Subject (fairness), and it must be for one of the purposes specified in the applicable Data Protection regulation (lawfulness).
Principle 2: Purpose Limitation
Personal Data shall be collected for specified, explicit and legitimate purposes and not further Processed in a manner that is incompatible with those purposes. This means WiredScore must specify exactly what the Personal Data collected will be used for and limit the Processing of that Personal Data to only what is necessary to meet the specified purpose.
Principle 3: Data Minimisation
Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are Processed. This means WiredScore must not store any Personal Data beyond what is strictly required.
Principle 4: Accuracy
Personal Data shall be accurate and, kept up to date. This means WiredScore must have in place processes for identifying and addressing out-of-date, incorrect and redundant Personal Data.
Principle 5: Storage Limitation
Personal Data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the Personal Data is Processed. This means WiredScore must, wherever possible, store Personal Data in a way that limits or prevents identification of the Data Subject.
Principle 6: Integrity & Confidentiality
Personal Data shall be Processed in a manner that ensures appropriate security of the Personal Data, including protection against unauthorised or unlawful Processing, and against accidental loss, destruction or damage. WiredScore must use appropriate technical and organisational measures to ensure the integrity and confidentiality of Personal Data is maintained at all times.
Principle 7: Accountability The Data Controller shall be responsible for, and be able to demonstrate compliance. This means WiredScore must demonstrate that the six Data Protection Principles (outlined above) are met for all Personal Data for which it is responsible.