Data Controllers

Stichting Microjustice4All,

Van Hogenhoucklaan 60D, The Hague

Netherlands

Data Protection Officer Contact Information

dpo@microjustice.org

Stichting Microjustice4All,

Van Hogenhoucklaan 60D, The Hague

Netherlands

Purposes of processing

We process your information to fulfil our contractual obligations to you, to comply with applicable laws, and to achieve our legitimate business interests. The legitimate interests include providing our services, preventing fraud, and securing the MicroJustice platform, and improving the MicroJustice platform and the services we offer.

Performance of contract with Users: name, email, phone number, password and authentication tokens, profile information and change history, business documents, availability data and change history, business information and case history.

Complying with applicable laws: postal codes, location data, business documents, business information, payout history.

Legitimate interests:

• Providing our service: name, email, password and authentication tokens, profile pictures, phone numbers, profile information and change history, business documents, availability data and change history, business information and case history.
• Preventing fraud and securing the MicroJustice platform: IP addresses, change history, location data, communication history and online behavior, government issued ID, professional and business licenses.
• Improving the MicroJustice platform and the services we offer: postal code, time zone, connected account Facebook, connected account Google ID, notification preferences, booking and booking status history, reviews, profiling and analytics, widget load statistics, location data.

Categories of recipients of the data:

We transfer your data to two types of recipients;

1.  Our processors, which enable us to provide and/or improve our services and store data;
2.  Other MicroJustice Users, which enables us to provide our services.

International transfer of data:

We transfer data outside the EU to be able to provide our services. We use agreements on the basis of EU Model Clauses (sets of clauses issued by the European Commission) to ensure an adequate level of data protection between Data Controllers.

Other information

We do not knowingly collect special categories of personal data and we urge our Users not to share such data while communicating via the MicroJustice platform. We do not knowingly process personal data from persons under the age of 18. If you become aware of a child sharing their data, please contact us so we can delete such data.

POLICY

MicroJustice provides this Privacy Policy to inform you of our policies and procedures regarding the processing, collection, use, and disclosure of personal information we receive from Users of MicroJustice, and any other products or services made available by MicroJustice. Under this Privacy Policy, MicroJustice is responsible for your information and is the Data Controller.

This Privacy Policy may be updated from time to time. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your MicroJustice Account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within the United States or internationally.

What Information We Process and Why

Under the General Data Protection Regulation, a Data Controller must have a legal basis for processing a Data Subject’s data. In the case of MicroJustice, we will process your information to adequately perform our contract with our Users (Data Subjects), to comply with applicable laws, and to fulfil legitimate interests we have in providing our service and running the MicroJustice platform.

Adequate Performance of Our Contact with Our Users

We collect the following data so that we can adequately perform the contract we have with our Users: name, email, phone number, password and authentication tokens, profile information and change history, business documents, availability data and change history, business information and case history.

Legitimate interests

Our legitimate interest in providing our service.

We process the following data so that we can provide our services: name, email, password and authentication tokens, profile pictures, phone numbers, bookings and booking history, fishing reports, review replies, listing information, and change history.

Our legitimate interest in preventing fraud and securing the MicroJustice platform.

We process the following data so that we can prevent fraud and secure the MicroJustice platform: IP addresses, change history, location data, communication history and online behavior, government-issued ID, professional and business licenses.

Processing this data enables us to operate the MicroJustice platform; provide Client service; and send our Users operative messages, updates, and account notifications. It also enables our Users to communicate and interact with MicroJustice Users and our team.

Processing this data enables us to detect and prevent fraud, abuse, security issues, and other activities which may be harmful for our Users or the MicroJustice platform, conduct security investigations and risk assessments, conduct checks against databases and other information sources, comply with legal obligations, resolve any disputes with our Users or between them, enables us to enforce our agreements with third parties, and enforce our policies and Terms of Use.

We may review, scan, analyze, and store all communication (including emails, phone calls, messages, etc.) sent or received using MicroJustice’s communication tools, (including communications with other Users) for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and remove references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve and expand product offerings. Automated methods are used whenever reasonably possible; however, we may need to manually review some communications occasionally. This may be done to provide support, conduct fraud investigations, as well as assess and improve the functionality of these automated tools. We will not review, scan, analyze, or store your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

We reserve the right to block the delivery of or review communications that we, at our sole discretion, believe may contain malicious content, spam, or that may pose a risk to you, our Users, MicroJustice, or others.

These communications and their contents may be disclosed in response to lawful government requests or legal processes, and in other circumstances in which we have good faith that a crime has been committed by the use of our services or that an emergency exists that poses a threat to the safety of our users or another person, if necessary to protect our rights or property, or in order for us to render the service you have requested.

To make sure that we work with licensed captains and guides, we may collect verification information such as your government-issued ID, or other authentication information.

Our legitimate interest in improving the MicroJustice platform and our services.

We process the following data so that we can improve the MicroJustice platform and the services we offer to our Users: postal/ZIP code, time zone, connected Facebook account, connected Google ID account, notification preferences, booking and booking status history, reviews, profiling and analytics, widget load statistics, NPS score, location data.

Processing this data enables us to measure the performance of our service, makes it easier for Users to log into their account, and personalizes the services to individual Users. Namely, Users may link their MicroJustice Account login information to MicroJustice through the Site, Service, or Application, or may allow MicroJustice to access Users’ Third-Party Account, as permitted under the applicable terms and conditions and that govern your use of each Third-Party Account. If you decide to register by logging into a Third-Party Account via our Site or Application, we may obtain the personal data you have provided to the applicable Third-Party Account and use that information to create your MicroJustice Account.

When you visit the Services, whether as a MicroJustice User or a non-registered user just browsing, our services automatically record information that your browser sends whenever you visit a website. This data may include information such as your computer’s IP address, browser type, or the webpage you visited before you came to our Services, pages, or features of our Services that you visit or use, the time spent on those pages, information you search for on our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the technical administration of the Services, to increase the functionality and user-friendliness of the Services, and to better tailor our Services to our visitors’ needs. We also use this information to verify that visitors to the Services meet the criteria required to process their requests. We do not treat this data as Personal data or use it in association with other Personal data, though we may aggregate, analyze, and evaluate such information for the same purposes as stated above regarding other non-identifying information.

If you are candidate for a position at MicroJustice, your personal data will only be processed for the purpose of candidate selection. Your personal data will be stored in our candidate database for up to 2 years (or until we offer you employment). Please read our whole Privacy Notice thoroughly.

Our legitimate interest in direct marketing purposes

We process the following data in order to provide our Users with direct marketing which may be useful to them: profiling and analytics data, and location data.

Complying with applicable laws

The following data we process to be able to comply with applicable laws: postal codes, location data, business documents and business information.

MicroJustice uses cookies, mobile identifiers, tracking URLs, log data, and similar technologies to help provide, protect, and improve the MicroJustice Platform Software, Website, and Services, hereafter referred to as the “Products”. This Cookie Policy (“Policy”) supplements the MicroJustice General Terms of Use and Privacy Policy and explains in more detail how and why we use these technologies, and the choices you have.

Why MicroJustice Uses These Technologies

We use these technologies for a number of purposes, such as:

• to enable you to use and access the MicroJustice Platform Products;
• to enable, facilitate, and streamline the functioning of and your access to the MicroJustice Platform Products;
• to better understand how you navigate through and interact with the MicroJustice Platform Products, and to improve the MicroJustice Platform Products;
• to monitor and analyze the performance, operation, and effectiveness of the MicroJustice Platform Products and MicroJustice advertisements;
• to enforce legal agreements that govern the use of the MicroJustice Platform Products;
• for fraud detection and prevention, trust and safety, and investigations;
• for purposes of our own support, analytics, research, product development, and regulatory compliance.

Cookies

When you visit the MicroJustice Platform Products, we may place cookies on your device. Cookies are small text files that websites send to your computer or other Internet-connected devices to identify your browser uniquely or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use the information we collect to better understand website traffic patterns and optimize our website experience. Sometimes, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the MicroJustice Platform Products or engage others to track your behavior on our behalf.

Types of Information Collected by Cookies

The types of information that we collect through Cookies include:

• IP address;
• Device ID;
• Viewed pages;
• Browser type;
• Browsing information;
• Operating system;
• Internet Service Provider;
• Whether you have responded to or interacted with an advertisement;
• Referring or referred links or URLs;
• Features used and activities engaged in on our sites and in our apps.

Types and Functions of Cookies:

Functional Cookies:

Functional Cookies enable our website to work properly, so you can create your account, sign in, and manage your bookings. They also remember your selected currency, language, past searches, and other preferences. These technical cookies must be enabled to use our site and services.

Analytics Cookies:

Analytics Cookies help us understand how Users use MicroJustice. This means we can improve our website, apps, and communications, and ensure we continue to be interesting and relevant.

Marketing Cookies:

MicroJustice and our trusted partners use third-party Cookies. These Cookies are used to display personalized advertisements both on MicroJustice and other websites. These adverts are based on your browsing, such as charter listings you have viewed. These cookies also integrate social media on our site, allowing you to like or share pages or products on social media.

Your Preferences

You can set or amend your web browser controls to accept or refuse Cookies whenever you like, but please remember if you do choose to reject Cookies, your access to some of the functionality and areas of our site may be restricted.

Complying with Applicable Laws

We process the following data in order to be able to comply with applicable laws: postal/ZIP codes, location data, business documents, business information, payout history.

How we Store and Secure the Information We Process

MicroJustice is very concerned with safeguarding your information. When you enter personal information on our registration or order forms, we encrypt that information. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Services, you can contact us via office@microjustice.org

How We Share Your Information

With other MicroJustice Users

When you create a MicroJustice Account, we will set up a MicroJustice Account profile page for you. Your MicroJustice Account profile page will include your first name and last name, and connections you have established between your Account and any TPAs, and a biography. You can select other items of Personal Information that you wish to be included in your MicroJustice Account profile page including, but not limited to, a profile picture and other information known as your “Profile Information”. We will display your Profile Information on your MicroJustice Account profile page publicly via the Services, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all MicroJustice Users and consequently should reflect how much you want other MicroJustice Users to know about you. We recommend that you guard your anonymity and sensitive information, and we encourage lawyers to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your Profile Information at any time.

If you request to make a case via the Services, MicroJustice will share the following information about you with the applicable Lawyer: (i) your first and last name, (ii) a link to your MicroJustice Account profile page where the Lawyer can view your request. All of this information will enable the Lawyer to decide whether to confirm or reject your case. When a Lawyer confirms a case, we will share pieces of the Lawyer’s Identify Information with the applicable User including, but not limited to, their full name and address, and we will share pieces of the User’s Identify Information with the Lawyer including, but not limited to their full name.

With processors

When we share your information with processors outside the EEA, we have – prior to sharing your information with such a corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection. This is done via agreements on the basis of EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection upon request.

MicroJustice cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of MicroJustice or a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be –or pose a risk of being – illegal, unethical or legally-actionable.

We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

How long we retain your data

We will retain your information as long as your account is active, as is necessary to provide you with the Services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and protect MicroJustice’s legal rights.

We also process and maintain aggregated, anonymized, or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services, or comply with legal obligations.

How to Control Your Information

You have rights to your own data and can request to have your information provided to you, changed, or erased. If you think that any of the information, we have on you is incorrect for any reason, please notify our Data Protection Officer to have it corrected. If you would like us to provide you with any or all of the data we have processed about you, please send a written request to dpo@microjustice.org and we will provide you with the information within 30 days. If you do not wish to receive notifications from MicroJustice, you can always change your preferences in your account Settings.

You have the right to lodge a complaint with your local Supervisory Authority.

If you wish to have your data removed, please send a request to dpo@microjustice.org or request to delete your profile and data directly from our Product an erasure directly from your profile. Please note that, while your data will be anonymized and not used on the platform any longer, some information which we are required to keep for tax purposes will be retained. Furthermore, we may keep some of your data, such as your name, email address, and phone number to ensure we no longer contact you.

Under the GDPR, you have the right to object to the processing of your personal information if it is processed on the basis of a business’s legitimate interest. If you object to such processing, MicroJustice will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or if such processing is necessary for the establishment, exercise, or defense of legal claims. Please note, however, that this may lead to difficulties in accessing some or all of our Services.

International Transfers of Data

We collect data globally and primarily store that information in the Netherlands. We transfer, process, and store your information outside of your country of residence to the Netherlands, and wherever our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

When we share your information with corporate affiliates or third-party service providers outside the EEA, we have – prior to sharing your information with such a corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This is done via agreements on the basis of EU Model Clauses (a set of clauses issued by the European Commission). We can provide further information on the means to ensure an adequate level of data protection upon request.

Other Important Privacy Information

Processing of special categories of personal data

MicroJustice does not knowingly or intentionally collect or process sensitive data (as defined in Art. 9 of the GDPR, namely: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation). We urge our Users not to share sensitive personal data about themselves or others over the MicroJustice platform. However, we are aware that some Users may divulge sensitive information about themselves while communicating through the MicroJustice platform. If we do come across such data, it will not be processed in any way by MicroJustice, Inc. We will use reasonable means to detect and remove such data.

Our policy towards children

Furthermore, the MicroJustice platform and application are not directed to individuals under 18. We do not knowingly process personal data from persons under the age of 18. If a parent or guardian becomes aware that their child has provided us with personal data without their consent, he or she should contact us. If you become aware that a person under the age of 18 has provided us with their personal data, please notify us via dpo@microjustice.org so that we can delete such information from our files.