Charley Privacy Statement
Navigating the digital world often raises personal data and privacy concerns. At Charley, recognition of these concerns is paramount. Being tracked online, collecting excessive data, and lacking control over one's digital information are unsettling prospects for many users. That’s why the bedrock principle upon which Charley is built is Respect for User Privacy. Transparency is a cornerstone of Charley's approach. When users engage with Charley, certain information is collected to enhance their experience. That information is collected, stored, and deleted differently according to type. As described below, User Data includes the user IP, Source URL (host website), City, Region, Country, Timezone, and Postal Code. ChatBot infers the City, Region, Country, Timezone, and Postal Code based on the user’s IP. Chat History includes both the bot and the user’s replies to a conversation. User Data and Chat History are stored as an encrypted backup before being deleted. Telemetry Data, which is not associated with user data or chat history and includes the user IP and host URL, is stored as an encrypted backup before being deleted. Charley steadfastly refrains from employing cookies, pixels, or other technologies to track users for marketing purposes. Moreover, while Charley may temporarily capture user data for service optimization, there is a strict policy to ensure all personal data is deleted after a limited period. On the user end, all Charley data is deleted when the user closes the browser window or refreshes the page. Charley also prides itself on adherence to international data protection standards, including the General Data Protection Regulation (GDPR) from Europe, the UK GDPR, the California Consumer Privacy Act (CCPA), and the Virginia Consumer Data Protection Act (VCDPA). Charley's policy is straightforward if these laws conflict – adopt the stricter, more protective standard. Charley is an online chatbot that connects people seeking information about abortion to accurate, up-to-date, and complete information about their abortion options. This privacy statement applies to the Charley chatbot and website provided by the Re/Imagination Lab] (“we,” “our,” or “us”), including https://chatwithcharley.org/ (the “Charley Sites”).
This privacy statement explains what personal information we collect from visitors to the Charley Sites, how we use and share that information, and the rights and choices you have in connection with that information, including how you can limit certain uses and sharing of your information. When we refer to “personal information,” we mean information about an identified individual or an individual we could identify. Subject to applicable law, personal information generally does not include publicly available information or anonymized or de-identified data.
This privacy statement does not apply to third-party websites, products, or services, even if they link to the Charley Sites or embed the Charley chatbot. We recommend you review the privacy practices of those third parties before connecting or accessing third-party websites and sharing any personal information. See the Links to Other Websites section for more information.
Without prejudice to your rights under applicable laws, this privacy statement is not contractual and does not form part of your contract with us or our affiliates or subsidiaries.
Table of Contents
This privacy statement is provided in a layered format. You can jump to a specific section by clicking on the section below.
- Who you are
- If you are a Charley Site Visitor
- If you are a Charley Chatbot user of if you load the Charley Chatbot
- Cookie, pixel, and session replay policy
- Aggregated, de-identified, or anonymous information
- Your choices
- Localization of data storage and processing
- Data security
- Links to other websites
- Children’s privacy
- Additional information for California residents
- Additional information for Colorado residents
- Updates to this privacy statement
- Contact us
Who you are
The types of personal information we collect, use, or disclose may vary depending on how and why you interact with the Charley Sites. This privacy statement applies to one of the following types of individuals and our collection, use, or disclosure of these individuals’ personal information:
A Charley Site Visitor: You visit or interact with the Charley Sites, whether or not with the Charley chatbot.
A Charley Chatbot User: You interact with the Charley chatbot, whether hosted on the Charley Sites or by a third party, or you load a page containing the Charley chatbot. For example, you visit a third-party website with the Charley chatbot installed.
You may be included in either or both of these categories.
If you visit the Charley Sites, you are a Charley Site Visitor, and the “If you are a Charley Site Visitor” section explains how we may collect, use, or disclose your personal information.
If you visit a third-party site that has the Charley chatbot, and you load the Charley chatbot or interact with the Charley chatbot, you are a Charley Chatbot User. The “If you are a Charley Chatbot User or load the Charley Chatbot” section explains how we may collect your personal information through the Charley chatbot and how we may use or disclose it.
If you visit a page on the Charley Sites that has the Charley chatbot, and you load the Charley chatbot or interact with the Charley chatbot, you are both a Charley Site Visitor and a Charley Chatbot User. As a Charley Site Visitor, the “If you are a Charley Site Visitor” section explains how we may collect, use, or disclose your personal information that we do collect through the Charley Sites other than through the Charley chatbot. And as a Charley Chatbot User, the “If you are a Charley Chatbot User or load the Charley Chatbot” section explains how we may collect your personal information through the Charley chatbot (but not otherwise through the Charley Sites) and how we may use or disclose that data.
We encourage you to read this privacy statement thoroughly. For more information, contact us using the information in the “Contact Us” section.
If you are a Charley Site Visitor
As a Charley Site Visitor, you visit and interact with the Charley Sites. It does not matter if you load or interact with the Charley chatbot. For example, if you visit https://chatwithcharley.org/ you are a Charley Site Visitor for those interactions. This section explains how we may collect, use, or disclose your personal information. If you load or interact with the Charley chatbot on our Sites, the “If you are a Charley Chatbot User or load the Charley Chatbot” section explains how we may collect your personal information through the Charley chatbot and how we may use or disclose that data.
Types of Personal Information We Collect About Charley Site Visitors and Why
We may collect the following categories of personal information about Charley Site Visitors for the purposes stated in the chart.
Category 1: Internet or other electronic activity information
Examples:
Device ID or IP address and user-generated content (including reviews and feedback)
Browsing history on the Charley Sites; clickstream data; browser and operating system type; navigation paths; data/time stamps; cookie identifiers; and other information about device characteristics and how you interact with the Charley Sites or our Services
Purpose of Collection and Use:
Provide and enhance the Charley Sites
Detect and prevent fraud
Comply with legal or regulatory obligations
Category 2: Geolocation data
Examples:
Geolocation data based on your IP address
Purpose of Collection and Use:
Provide and enhance the Charley Sites
Detect and prevent fraud
Comply with legal or regulatory obligations
How We Collect Information About Charley Site Visitors
We may collect personal information about Charley Site Visitors from the following sources:
Source 1: Directly from you
We may collect personal information from you when you interact with the Charley Sites or our services, submit inquiries or request information from us, or otherwise contact or communicate with us.
Categories of Personal Information We Collect:
Identifiers
Internet or other electronic activity information
Geolocation data
Electronic information
Source 2: Automatically
We may collect personal information from you automatically when logged in, you visit the Charley Sites, as you load the Charley Sites, or as you interact with us. See the Cookie section.
Categories of Personal Information We Collect:
Internet or other electronic network activity
Geolocation data
Parties to Whom We May Disclose Information About Charley Site Visitors
We disclose personal information about Charley Site Visitors as follows:
Recipient Category 1: Our service providers and third-party vendors
We use third-party vendors to perform operational functions related to the Charley Sites. Some of these vendors (e.g., hosting providers) may have access to your personal information, but only as necessary to provide services to us. If the third-party vendor is our service provider, we have agreements in place with the vendors requiring your information to be kept confidential and reasonable data security measures used to protect it. We also share your personal information with vendors (for example, hosting providers) as needed to assist us with business operations, but in such instances, these vendors are contractually required to keep your information confidential.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Electronic information
Recipient Category 2: Government entities
We may share personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or the protection of the rights, property, or safety of our company or third parties.
We may also share personal information in relation to a known or suspected violation of our terms of use, fraud prevention, or other unlawful use, including with entities assisting us with an investigation, or as may be required by applicable law.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Electronic information
Recipient Category 3: Business partners
We may engage third parties to perform certain functions on our behalf. To do so, we may disclose personal information to our third-party business partners and service providers to maintain and operate the Charley Sites and services and provide, improve, and personalize the Charley Sites and services, including to fulfill requests for the Services, and for other technical and processing functions, such as sending emails on our behalf and technical support.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Electronic information
Recipient Category 4: Successor organizations
Subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in this privacy statement.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Electronic information
If you are a Charley Chatbot user of if you load the Charley Chatbot
Charley Chatbot Users are individuals who load the Charley Chatbot on a page, whether on the Charley Sites or on a third-party site, or who interact with the Charley chatbot. This section explains how we may collect personal information through the Charley chatbot and how we may use or disclose that information.
Types of Information We Collect About Charley Chatbot Users and Why
We may collect the following categories of personal information about Charley Chatbot Users for the purposes stated in the chart.
Category 1: Identifiers
Examples:
Device ID; or IP address
Purpose of Collection and Use:
Provide and enhance the Charley Sites and Services
Customize your experience
Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
Comply with legal or regulatory obligations
Category 2: Internet or other electronic activity information
Examples:
Clickstream data; browser and operating system type; navigation paths; data/time stamps; cookie identifiers; or other information about device characteristics and how you interact with the Charley chatbot
Purpose of Collection and Use:
Provide and enhance the Charley Sites and Services
Customize your experience
Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
Comply with legal or regulatory obligations
Category 3: Geolocation data
Examples:
Geolocation data based on your IP address
Purpose of Collection and Use:
Provide and enhance the Charley Sites and services
Customize your experience
Detect and prevent unauthorized access, security incidents, fraud, or other illegal or malicious activity
Comply with legal or regulatory obligations
Category 4: Sensitive personal information
Examples:
Health information (date of last period)
Purpose of Collection and Use:
Provide and enhance the Charley Sites and services
Customize your experience
Comply with legal or regulatory obligations
How We Collect Information About Charley Chatbot Users
We may have collected personal information about Charley Chatbot Users from the following sources stated in the chart.
Source 1: Directly from you
We may collect personal information from you when you interact with the Charley chatbot.
Categories of Personal Information We Collect:
Identifiers
Internet or other electronic activity information
Geolocation data
Sensitive personal information
Source 2: Automatically
We may collect personal information from you automatically when you load the Charley chatbot or as you interact with the Charley chatbot. We store data we collect automatically about Charley Chatbot Users in an identifiable form for a certain period. In special circumstances, like extended investigations, we may preserve data longer. We store aggregate statistics about the use of content delivery networks indefinitely, but those statistics don't include data identifiable to you personally.
Categories of Personal Information We Collect:
Internet or other electronic network activity
Geolocation data
Parties To Whom We May Disclose Personal Information About Charley Chatbot Users
We disclose personal information about Charley Chatbot Users as follows:
Recipient Category 1: Our service providers and third-party vendors
We use third-party vendors to perform operational functions related to the Charley chatbot. Some of these vendors (e.g., hosting providers) may have access to your personal information, but only as necessary to provide services to us. If the third-party vendor is our service provider, we have agreements in place with the vendors requiring your information to be kept confidential and reasonable data security measures used to protect it. We also share your personal information with vendors (for example, hosting providers) as needed to assist us with business operations, but in such instances, these vendors are contractually required to keep your information confidential.
We may share personal information with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Sensitive personal information
Recipient Category 2: Government entities
We may share personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud or crime-prevention purposes or for the protection of the rights, property, or safety of our company or third parties.
We may also share personal information in relation to a known or suspected violation of our terms of use, fraud prevention, or other unlawful use, including with entities assisting us with an investigation or as may be required by applicable law.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Sensitive personal information
Recipient Category 3: Business partners
We may engage third parties to perform certain functions on our behalf. To do so, we may disclose personal information to our third-party business partners and service providers in order to maintain and operate the Charley Chatbot and services and provide, improve, and personalize the Charley chatbot and services, including to fulfill requests for the Services, and for other technical and processing functions, such as sending emails on our behalf and technical support.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Sensitive personal information
Recipient Category 4: Successor organizations
Subject to applicable law, we reserve the right to transfer some or all personal information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. If any such transaction occurs, the purchaser will be entitled to use and disclose the personal information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding personal information as described in the privacy statement.
Categories of Personal Information We May Share:
Identifiers
Internet or other electronic activity information
Sensitive personal information
Additional Information For Charley Chatbot Users
We may use aggregated, de-identified, or anonymized information about how you use the Charley chatbot or from which domains or websites you load the Charley chatbot to improve the functionality of the Charley chatbot and improve our service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends. Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not personal information or subject to this privacy statement.
Cookie, pixel, and session replay policy
Usage Info and Cookies
When you access the Charley Sites (including loading or interacting with the Charley chatbot), our servers automatically collect and record the Internet Protocol (“IP”) address associated with your computer. We may also collect additional information such as a device ID, browser type and version, the operating system of your device and language, and country, the date and time of visits, your IP address, the pages viewed, time spent on the Charley Sites, and the websites visited just before and just after a Charley Site. This information is used to help us administer the Charley Sites. This information may be appended to your profile information to remember your preferences and diagnose technical problems.
To collect this information, we use cookies. Cookies are small data files sent by a website and stored on the computer or device at the request of that site. Cookies store information related to a user's browser to enable us to recognize your device on return visits to the Charley Sites and to remember your preferences.
Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. If you want to block the use and saving of cookies from the Charley Sites onto the computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Services and external serving vendors. Please note that if you choose to erase or block your cookies, certain parts of our Services may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.
We may also use web beacons, pixels, or similar collection mechanisms, and in certain circumstances, we may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.
Do-Not-Track
The Charley Sites do not support Do-Not-Track functionality. Do-Not-Track is a preference you can set on your web browser to inform websites that you do not want to be “tracked’ by third parties. Charley does not respond to Do-Not-Track Signals as it does not track you when you leave a Charley Site. Charley's third-party service providers may not respond to Do-Not-Track signals. If an individual comes to a Charley Site directly with a Do-Not-Track signal enabled on such individual's browser, Charley does not look for or respond to the Do-Not-Track signal.
Aggregated, de-identified, or anonymous information
We may create aggregated, de-identified, or anonymous information from personal information by removing certain data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable or through aggregation, obfuscation or other means. For example, we may use aggregated, de-identified, or anonymized information to understand how to improve or enhance the Charley Sites (including the Charley chatbot). Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not personal information or subject to this privacy statement.
Your choices
You have certain choices with respect to your personal information.
Update Your Communications Preferences
We may use your contact information to send you email messages regarding updates to the Charley Sites, such as the publication of new Charley information and content promotional offers, or to communicate with you about the Charley Sites. You may opt out of receiving these emails at any time via the unsubscribe link contained in the email message.
Charley will communicate with you only according to your preferences provided to us. We may use your contact information to send you messages regarding updates to the Charley Sites. You may opt out of receiving these messages by following the unsubscribe link contained in the message or by contacting our customer support team at privacy@reimaginationlab.org. Please be advised that you may not be able to opt out of receiving certain messages from us, including legal notices.
Exercise Rights Based On Your State Of Residency
Residents of certain states may have additional or different rights as described elsewhere in this privacy statement.
In order to opt out of third-party communications, you will need to contact the applicable third party. If you have any questions relating to opting out, please contact us at privacy@reimaginationlab.org.
Localization of data storage and processing
The Charley Sites are operated in the United States. If you are located outside of the United States, any information you provide to us will be transferred to, processed, and/or maintained in the United States. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information and services and/or to perform any requested transaction.
Data security
We have taken steps to secure and protect your personal information from loss, unauthorized access, unauthorized disclosure, misuse, destruction, or alteration. However, there is always some risk involved in transmitting information over the Internet, and we cannot fully eliminate security risks associated with storing and transmitting personal information.
Links to other websites
The Charley Sites contain links to other websites, including social networking websites, mobile applications, or Internet locations (collectively “Third-Party Sites”). The fact that we link to a website is not an endorsement or representation of an affiliation with that website. We have no control over and are not responsible for third-party websites, privacy practices, content, or any goods or services available through the Third-Party Sites. Our privacy statement does not apply to Third-Party Sites; any information you provide to a Third-Party Site is subject to that Third-Party Site’s privacy policy or privacy statement. You should carefully review the applicable privacy policies or statements before using or engaging with any Third-Party Site on any Charley Sites.
The Charley Sites may include social network sharing widgets that may provide information to their associated social networks or third parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the widget appears. If you use social networking tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.
Children’s privacy
The Charley Sites and the services offered are not directed to or intended for use by children under 13 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for our services, without parental consent. No one under age 13 may provide any personal information to Charley or on the Charley Sites. If you are under 13, please do not attempt to register for the Charley Sites or send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have inadvertently collected personal information from an individual under age 13 without parental consent, we will take steps to delete the data as permitted by law. If you believe that we might have any information from or about an individual under age 13, please contact us at privacy@reimaginationlab.org.
Additional information for California residents
Under California’s “Shine The Light” law (California Civil Code § 1798.83), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their personal information may be disclosed to third parties and, in some cases, affiliates, for those third parties and affiliates’ direct marketing purposes. Under this law, a business is to either provide California customers certain information upon request or permit California customers to opt out of this type of disclosure. You may request this information by contacting us at privacy@reimaginationlab.org and indicating in the email subject line, “California Shine The Light Request.” Please include your mailing address, state of residence, and email address with your request.
As a non-profit organization, we are not subject to the California Consumer Privacy Act, as amended.
Additional information for Colorado residents
Your Rights Under The Colorado Privacy Act
We are subject to the Colorado Privacy Act based on our interactions with Colorado residents and our use of their personal information. The Colorado Privacy Act provides Colorado residents enhanced rights with respect to their personal information when acting in an individual or household context. In this section, "CPA personal data” refers to personal information that is linked or reasonably linkable to an identified or identifiable Colorado resident. CPA personal data does not include de-identified or publicly available information, as defined in the Colorado Privacy Act.
First, a Colorado resident may opt out of processing their CPA personal data for targeted advertising, selling their CPA personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning that Colorado resident.
Second, a Colorado resident has the right to confirm whether we are processing CPA personal data concerning them and to access their CPA personal data. As part of a request for access, the Colorado resident may also request to receive their CPA personal data in a portable, readily usable format if technically feasible.
Third, Colorado residents may have the right to correct inaccuracies in their CPA personal data we hold.
Fourth, a Colorado resident may have the right to request we delete CPA personal data concerning them.
To exercise your rights, please fill in our online web form or email us at privacy@reimaginationlab.org. If you email us, please put in the subject line of your email the right you are seeking to invoke: “Right to Opt-Out,” “Right to Access,” “Right to Correct,” or “Right to Delete.”
You may submit multiple requests at once through our web form or in an email. There is no cost for submitting your first request; if you submit multiple requests in twelve months, we may charge you a fee for answering your request. We are permitted to use commercially reasonable efforts to authenticate you are who you say you are, and if you are submitting the request on behalf of another, you have the authority to do so. So, we may need to ask you for more information in light of the rights exercised, the type, sensitivity, value, or volume of personal data, the level of possible harm if we improperly grant the request, and the cost to us. We will deny the request if we cannot authenticate you or your authority.
If you submit a request, we will tell you the result of your request (including if you submit a Right to Access, your personal data) without undue delay and within 45 days after receiving your request. In some cases, we may extend that deadline by 45 days to 90 days in total. If we extend the deadline, we will tell you that and why.
The Colorado Privacy Act includes exceptions for personal data regulated under other laws or maintained for certain reasons or in certain contexts. For example, the Colorado Privacy Act does not apply to publicly available information, including information we reasonably believe Colorado residents have lawfully made available to the general public. As another example, we will not delete personal data when it is necessary to maintain that personal data to comply with a legal obligation.
If we don’t grant your request, we will tell you why we did not. You may appeal our decision by emailing us at privacy@reimaginationlab.org with the subject line “Appeal of Request” and including our response to your request. We will also include this information in our response to your request. If you appeal our decision, we have 45 days to respond. In some cases, we may also extend our deadline by 45 days to 90 days in total. If we extend the deadline, we will tell you that and why. If you have concerns about the results of your appeal, you may contact the Colorado attorney general.
Additional Colorado Mandatory Disclosures
We may collect, use, and disclose personal data revealing a physical health condition or diagnosis, particularly the date of your last period, through the Charley chatbot, which is sensitive data under the Colorado Privacy Act. How we may use and disclose the date of your last period is described above in the If You Are a Charley Chatbot User Or If You Load The Charley Chatbot section. If, based on your IP address, you may be in Colorado, we will inform you of your right to consent when requesting that information and ask for your consent before asking for the date of your last period. We will not ask you for that date if you decline to provide consent. After 24 months, if you are no longer interacting with us and we still have the date of your last period associated with you (or your IP address), we will seek your consent again to continue using or disclosing it. If you wish to withdraw your consent after giving it, please contact us using the information in the Contact Us section.
We do not otherwise collect sensitive data under the Colorado Privacy Act.
When you visit our website, we may use the information we collect automatically through online interactions, as described above in the Cookie, Pixel, and Session Replay Policy section, for targeted advertising, which we may disclose or make available to advertising and social media networks.
Updates to this privacy statement
We may update this privacy statement from time to time. The “effective date” at the top of this privacy statement indicates when this privacy statement was last revised. Any changes are effective when we post the revised privacy statement on the Charley Sites. We encourage you to review this privacy statement to learn about updates to our privacy practices.
Contact us
For any questions or assistance, please reach out to us at privacy@charleybot.org.