Privacy Policy for Avalon Internet
San Francisco, California, USA
Database in Montreal, Canada
Members World-Wide
Private List is a project of Avalon Internet
Effective on August 24, 2005
This policy establishes how Avalon Internet handles information it learns about visitors to and members of the private-list.com website. Protection of privacy is a fundamental business value of Avalon Internet.
Its policies comply with:
Organization for Economic Co-operation and Development (OECD)
Guidelines on the Protection of Privacy and Transborder Flows of Personal Data
the agreement between the USA and the European Union
known as the
International Safe Harbor Privacy Principles
and associated Frequently Asked Questions
Canada's
Personal Information Protection and Electronic Documents Act
Quebec's
Act Respecting the Protection of Personal Information in the Private Sector
Click on any part of the table of contents to move directly to the part of the policy addressing that issue.
Table of Contents
- What personal information does Avalon Internet collect and for what purposes is it used?
- How is it collected?
- How can it be corrected?
- Where is it kept?
- How is it secured?
- Who has access to or uses it?
- To whom is it disclosed?
- When is it disposed of?
- What non-personal information is collected and for what purposes is it used?
- Do the actions of Avalon Internet conform to this policy?
- What happens in case of a dispute?
- Notice of changes to this policy
- Contact Avalon Internet regarding this policy
- Links to other sites
Private List is a membership site that offers members' own listings of great places in cities they know well, the opportunity for members to post queries about places they plan to visit, and an optional context in which members can meet each other on their travels. The site is not directed to children, and the page on which personal information is entered requests that viewers be aged at least 18 to participate.
What personal information does Avalon Internet collect and for what purposes is it used? |
Private List uses personal information from its visitors for the purposes listed below. The information will not be used for any other purpose without previous consent. Every record in the Private List database explicitly indicates the purpose for which that record must be used.
Generally speaking, personal information is used:
A travel contact posting can be initiated by members, indicating a member's readiness to be contacted personally by other members who plan to visit a city. On this posting appears personal demographic information supplied by the member, including the member's gender, age range, languages spoken, activity offered to share, and a biographical summary. The member can also list areas in which he or she is looking for information from others.
The Private List site keeps a running record of which members have sent messages to which other members using this feature, and the date of their having done so, in order to alert someone using the contact form that he or she has already sent a message to that person, and when. The file also provides a record for complaint investigation.
To maintain the continuity of a visit, Private List software writes a temporary "session cookie". A session cookie is a short file saved on a viewer's computer that causes his or her browser to send an identification code with every request for a new page on the site that installed the cookie. The session cookie expires at the end of the visit, and the browser will no longer send that identifier. If the viewer's browser is set not to accept cookies, the Private List software maintains the session in another way, by adding the session identification code to the address of every subsequent page requested by the viewer on its site. It is visible in the address line of the viewer's browser. This is somewhat less secure during the time of the visit, since another person might be able to read the code electronically as it is sent.
Specifically, the Private List site collects:
the member's | which is used to |
|---|---|
salutation | greet a member when he or she enters the site, address e-mail messages to the member with regard to individual listings the member has posted, correspond with a member regarding site operation |
site pseudonym | a unique name chosen by the member identifying his or her listings and postings on the site; also used to identify the sender of a message to another member |
e-mail address | respond to queries from the viewer, contact members with regard to individual listings the member has posted, contact members as other issues arise with respect to site operations; used as the 'reply to' address on member-generated communications to other members |
a unique number assigned to each guest and member as an ID | activate all member-specific features of the site |
the date joined | track membership |
the date a listing was last updated | display on listings |
Optionally, a member can enter: | |
a brief biography | display a description of the member from his or her travel contact posting |
gender | provide information to those proposing to meet the member |
age | provide information to those proposing to meet the member |
languages spoken | provide information to those proposing to meet the member |
activity offered | provide information to those proposing to meet the member, review by management for inappropriateness |
a request for information | inquiry for information from other members |
an ongoing list of listings chosen to be printed | print the listings a member has chosen |
a record of the last city for which a listing was posted | avoid members' having to repeatedly re-enter some data on the add-listing form |
Ongoing record of a guest or member's activity on the site: | |
the content of a member's posted listings and queries | display for other members and guests, review by management for inappropriateness |
an ongoing record of members contacts using the travel contact feature | remind members they have previously contacted a member offering to be a travel contact, provide a record for complaint investigation |
Provision of all personal information is voluntary. By pressing the submit buttons or using the program features described here, each visitor expresses consent for use of the information for purposes stated in this policy.
Most personal information is collected from forms on the Membership page. Information collected as a result of using the site, such as the record of dates of travel contact messages, is recorded as a result of specified actions of the viewer. If the viewer is not a member and contacts the Private List webmaster, information about him or her is collected in the webmaster's mail program. In all cases, collection is at the active choice of the visitor, known as an "opt_in" choice.
Temporary "session cookies", which individually identify a viewer, are recorded depending on whether the viewer has set his or her browser to accept them.
All personal information provided by members is available at all times on the Membership page. Listings can be corrected on the Add/edit/delete listing page.
Information arising out of site operation may be corrected by contacting the webmaster.
All Private List information is kept in Avalon Internet's Private List database, located on its server in Montreal, Canada. A back-up copy is kept at the organization's main location in San Francisco, California, USA. It is available to members world-wide through the Internet.
Security measures are in place to ensure the confidentiality of the information provided to Private List, and to to protect it from loss, misuse and unauthorized access, disclosure and alteration. Private List's server is protected by a firewall and anti-hacker technology. Backup copies of the database are kept both in Montreal and in a secure location in San Francisco. Access to an individual's personal information in the database requires entry of both user name and password. On log-in, the password is encrypted before being sent to the server for validation rather than sent in human-readable form over the Internet. Security is constantly being monitored and these practices may be changed from time to time to improve the security of the site and its data.
The individual Private List member or guest and the Private List webmaster, or his or her designees, are the only people authorized to have controlling access to a visitor's personal information and listing content.
Neither personal nor non-personal information is used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual.
If the member chooses to enter his or her name as the link on his listings, and/or biographical information for the contact program, these will be displayed to all site visitors. The member can also use a pseudonym. Other members contacting the posting member are not shown the poster's email address or private salutation. The email address and screen name (but not private salutation) of the member sending the message are disclosed to the recipient, for the purpose of replying.
Private List staff other than the webmaster may have access to the identities and email addresses of correspondents in order to respond to inquiries.
When a member resigns from Private List, all trace of that member is erased from the database.
Information provided by a viewer on the contact form is used only for subsequent relevant correspondence. Private List selectively archives correspondence from members or others as required for its business purposes.
What non-personal information is collected and for what purposes is it used? |
Browser software automatically sends to servers a great deal of technical information, none of which is personally identifiable. For each page request received by the Private List server, the following information is collected and stored:
This information is either used immediately by the sever to enable it to properly fulfill the page request or cumulated and used in the aggregate by Avalon Internet staff as statistical data for all visitors over a chosen time-frame.
It is used for such purposes as determining how the page should be displayed depending on which make of browser has requested it (for instance, default print sizes and aspect ratios are different in different browsers); analyzing the usefulness of various pages on the site from the rates at which they are visited; improving the site's accessibility from information about the other sites or search engines sending visitors to the Private List site; increasing available bandwith if the server is becoming overloaded with page requests; and broadening the geographic scope of visitors.
The logs may be preserved indefinitely and used at any time and in any way necessary to prevent security breaches and to insure the integrity of the data on Avalon Internet servers, to refine site design, and for any other business purpose.
Under the terms of the Safe Harbor Principles, Avalon Internet uses a self-assessment approach to verify that this policy is accurate, comprehensive, prominently displayed, completely implemented and accessible.
All staff is fully trained in implementation of this privacy policy and there are disciplining measures for failure to follow it. Avalon Internet has in place internal procedures for periodically conducting objective reviews of compliance with the above. A statement verifying the self-assessment is signed annually by the principal web developer and is available upon request by individuals or in the context of an investigation or a complaint about non-compliance.
Avalon Internet retains records on the implementation of its safe harbor privacy practices and will make them available upon request in the context of an investigation or a complaint about non-compliance to the independent body responsible for investigating complaints or to the agency with unfair and deceptive practices jurisdiction.
Individuals who wish to file a complaint or make an inquiry regarding the use or disclosure of their personal information should send such communication in writing in English, French or Spanish to:
Private List Safe Harbor Inquiry
433 Linden Street
San Francisco, California 94102 USA
Avalon Internet will investigate and attempt to resolve complaints and disputes in accordance with the principles contained in this policy.
For complaints that cannot be resolved between Avalon Internet and the complainant:
- If the complaint is generated anywhere other than the European Union, investigation of unresolved complaints is referred to the Federal Trade Commission (FTC) of the United States.
- If the complaint is generated in the European Union, Avalon Internet will cooperate with the European Union Data Protection Authorities (DPAs) in the investigation and resolution of complaints brought under the safe harbor. It will comply with any advice given by the DPAs where the DPAs take the view that the organization needs to take specific action to comply with the Safe Harbor Principles, including remedial or compensatory measures for the benefit of individuals affected by any non-compliance with the Principles, and will provide the DPAs with written confirmation that such action has been taken.
- If the complaint is generated in Canada, as well as cooperating with any FTC investigation, Avalon Internet will cooperate with the Commission d'accès à l'information, Quebec, or the Privacy Commissioner of Canada, as appropriate.
If a material (non-editorial) change is made to this privacy policy, a notice will be posted on the Private List site so users are aware of the change.
For additional information, please contact Avalon Internet by sending an email to privacy@private-list.com, by calling 415-864-2089, or by sending a letter to:
Ms. Beryl Magilavy
Private List Privacy Program
433 Linden Street
San Francisco, California 94102 USA.
The organization is available by fax on appointment, at the telephone number above. Ms. Magilavy serves as "data controller" for Avalon Internet and is responsible for its compliance with this privacy policy.
The Private List site contains links to other web sites. Please note that clicking these links takes the viewer to an unrelated site, which operates under a privacy policy other than this one, or perhaps no thought-through privacy policy at all. While these linked pages will have received no personal information from Private List, Avalon Internet notes that it has no liability for misuse of any information by any Web site controller to which it links.
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Persistent cookies
Avalon Internet does not use "persistent cookies"—those that remain active between visits to a site—or any other persistant tracking methods to collect personally identifiable information about visitors to its Web sites. Persistent cookies are commonly used to allow the Internet site to identify a previous visitor each time he or she visits the site or to track a viewer's movements through many Web sites. This latter type of cookie is often called "spyware."
Children who submit personal information
Private List does not wish to offer membership, which entails receiving personally identifiable information, to anyone under age 18. Knowingly collecting such information from children under age 13 is prohibited by the USA's Children's Online Privacy Protection Act of 1998, so we wish not to receive it in any form, including email messages, from such young children. If a guardian becomes aware that his or her child has submitted such information, he or she should contact the Private List webmaster to have it removed from the database.