This Privacy Policy is edited by American Society of Evidence-Based Policing, a having its registered office at [22990 Green Pine Dr, Canyon Lake, CA 92587 and registered under the number 82-2775225 (hereafter, the “Data Controller”).

The Data Controller offers a platform, American SEBP, (hereafter, the “Platform”) to its users which have subscribed on the Platform and as such have a user account (hereafter, the “Users”). The Platform is available at the following url address Americansebp.org

The Data Controller uses a solution called “Hivebrite”, which enables the import and export of user lists and data, the management of content and events, the organization of emailing campaigns and opportunity research and sharing as well as the management of funds and contributions of any kind.

In this regard, the Data Controller collects and processes User’s personal data in accordance with the Privacy and Cookie policy.

The Data Controller is particularly aware and sensitive with regards to the respect of its Users privacy and personal data protection. The Data Controller commits to ensure the compliance of the processing it carries out as data controller in accordance with the Data Protection Law.

The Data Controller has put in place an appropriate privacy and cookie policy to be fully transparent on how the personal data of Users are processed within the use of the Platform and services provided.

This privacy policy is intended for the Users of the Platform of the Data Controller.

 

Date of last update: 3/18/2025.

 

ARTICLE 1.                COLLECTED PERSONAL DATA

 

1.1 When subscribing on the Platform

When subscribing to the Platform, the User is informed that its following personal data is collected for the purpose of creating a user account:

Mandatory data

-       First name ;

-       Last name ;

-       Email address;

-       Gender

-       Summary

-       Skills

 

The User is informed that it is not possible to access the Platform without providing the mandatory data strictly necessary to create an account and authenticate the User.

 

1.2 During the use of the Platform

The User may validly publish, at its own initiative, any content on the Platform which shall be kept by the Company:

[To be completed by customer]

-        Posts

-        Events

-        Comments

The User is aware that when using the Platform, the User may decide to provide « sensitive data » within the meaning of Data Protection Law, for example, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, concerning sexual orientation, etc. By providing such sensitive data, the User agrees to their processing by the Platform in the conditions set forth in this Privacy Policy.

    

ARTICLE 2.                THE PURPOSE OF THE DATA PROCESSING

The Data Controller and its subcontractors process personal data that are freely transferred by the User when accessing the services proposed by the Platform for the following purpose:

 

Purpose

Legal basis

Creation and management of a user account;

·  Creation and Management of a User Account

  • Contractual Necessity: Under contract law, processing personal data to create and manage an account is typically justified because it is necessary to fulfill the agreement between the platform and the user.
  • Computer Fraud and Abuse Act (CFAA) (18 U.S.C. § 1030): Ensures that unauthorized access to user accounts is prevented.
  • State Laws (e.g., California Consumer Privacy Act - CCPA, Virginia Consumer Data Protection Act - VCDPA): May impose additional requirements on account management, such as data deletion rights.

·  Providing Platform Functionalities (Invitations, Offers, Events)

  • User Consent (15 U.S.C. §§ 6501–6506 – Children’s Online Privacy Protection Act, COPPA): If involving minors, explicit parental consent is required for data collection and invitations.
  • Federal Trade Commission Act (15 U.S.C. § 41 et seq.): The FTC enforces consumer protection laws against unfair or deceptive business practices, requiring transparency in data use.
  • CAN-SPAM Act (15 U.S.C. § 7701 et seq.): Regulates the sending of commercial emails and requires users to opt-in to receive marketing communications.
  • Telephone Consumer Protection Act (TCPA) (47 U.S.C. § 227): If sending SMS invitations or calls, explicit consent may be needed.

·  Sending Commercial Offers & Partner Promotions

  • CAN-SPAM Act: Requires users to opt-in to receive commercial messages and provides them with an opt-out mechanism.
  • California Consumer Privacy Act (CCPA) & California Privacy Rights Act (CPRA): If operating in California, users must be informed about the sale or sharing of their personal data for commercial purposes and given the ability to opt-out.
  • General Data Protection Regulation (GDPR, if applicable to U.S. businesses dealing with EU users): Requires explicit consent for marketing emails and sharing personal data with partners.

· Inviting Users to Events Organized by the Platform

  • Implied Consent / Legitimate Interest: If the event is a core function of the platform, invitations may be justified under implied consent.
  • TCPA & CAN-SPAM Act: If invitations are sent via text or email, they must comply with consent and opt-out requirements.
  • State Privacy Laws (e.g., CPRA, VCDPA, Colorado Privacy Act - CPA): May require businesses to allow users to withdraw consent for event-related communications.

 

Providing the User with all functionalities of the Platform, meaning:

●      Sending invitations for events organized by Data Controller or other Users, if the User has accepted to receive such invitations;

●      Sending offers [jobs / commercial offers – if applicable] from the Data Controller or its partners if the User has accepted to receive such offers.

●      Invite the User to events organized by the Platform

 

 

Management of data subjects rights according to the Personal Data Legislation.

Storage of User personal data;

 

If applicable: [Management of prospection operations:

●      Sending email prospect campaigns in the Name of Customer] and/or its commercial partners

●      Sending newsletters in the Name of Customer] and/or its commercial partners

 

Making statistics in order:

●      to improve the quality of the services proposed by the Platform;

●      improve the usage functionalities of the Platform;

 

Making statistics regarding the effective use of the Platform

Making statistics regarding the different levels of activity on the Platform.

 

Please note that Kit United, and its subsidiaries – in charge of providing the platform and managing its technical aspects - also collect your personal data as data controller, in order to generate statistics on the use of the platform. This processing is based on the data controller’s legitimate interests to improve the platform. The personal data are retained for the duration of the contractual relationship between Kit United and the Data Controller, plus 90 days.

 

 

ARTICLE 3.                 DATA RETENTION PERIOD

The Data Controller informs the User that the personal data related to the User Account is retained only during the length of the User’s subscription on the Platform.

Following the termination of said subscription, the personal data collected upon the subscription on the Platform shall be deleted after a period of 1 calendar year.

 

ARTICLE 4.                DATA TRANSFERS

The Users’ data are stored in the European Economic Area (EEA) by the Data Controller, [its subsidiaries and its trusted service providers. However, depending on the processing, the Users’ data may also be transferred in a country outside the EEA, to our trusted service providers [and/or subsidiaries].

When transferring data outside the EEA, the Data Controller ensures that the data are transferred in a secured manner and with respect to the Data Protection Law. When the country where the data are transferred does not have a protection comparable to that of the EU, the Data Controller uses “appropriate or suitable safeguards”.

When the service providers to whom personal data are transferred, are located in the United States, these transfers are governed by the standard data protection clauses adopted by the Commission.

Users can contact the DPO at the following address [email protected].

Personal data transfers may take place outside the EU/EEA in order to ensure the functioning of the solution. Indeed, Hivebrite uses third party services providers located outside the EU for the following purposes:

-        hosting of personal data, including image, profile pictures, backups, etc.;

-        production and storage of error logs enabling Hivebrite’s developers to correct the code;

-        sending of emails;

-        customer supports;

-        direct messaging module;

-        analysis of the User’s journey of the platform.

The country outside the EU/EEA where your personal data may be transferred are:

-        United Kingdom;

-        Switzerland;

-        The United States of America;

-        Australia.

These transfers are based on one of the following guarantees:

-        an adequacy decision, regarding personal data transfers to the United Kingdom and Switzerland;

-        the Standard Contractual Clauses of the EU Commission (available here);

-        your consent.

 

 

ARTICLE 5.                  COMMITMENT OF THE DATA CONTROLLER

The Data Controller commits to process User’s personal data in compliance the Data Protection Law and undertake to, notably, respect the following principles:

-        Process User’s personal data lawfully, fairly, and in a transparent manner;

-        Only collect and process the Users’ data for the strict purpose as described under article 2 of the present privacy policy;

-        Ensure that the personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

-        Do the best efforts to ensure that the personal data processed are accurate and, if necessary, kept up to date and take all reasonable steps to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

-        Keep personal User’s data for no longer than is necessary for the purposes for which they are processed;

-        Put in place all necessary technical and organizational appropriate measures in order to ensure the security, confidentiality, integrity, availability and the resilience of the process systems and services;

-        Limit the access to the Users’ data to the persons duly authorized to this effect;

-        Guarantee to the Users their rights under the Data Protection Law in relation to the processing of their data and make the best efforts to satisfy any request, where this is possible.

 

ARTICLE 6.                EXERCISE OF THE USERS’ RIGHTS

The User is duly informed that it disposes at any time, depending on the legal basis of the processing, a right to access, to rectification, to erasure, to restriction of processing, to data portability, and to object.

When processing is based on User’s consent, the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

The User can exercise its rights by sending an email to the following address [email protected] or by mail at the following address 31566 Railroad Canyon Rd, Canyon Laken CA 92587 provided that the User justifies his/her identity.

In addition, in the event the User considers that its rights have not been respected, the User of which the personal data is collected can lodge a complaint before the competent supervisory authority. For any additional information, you can review your rights on the websites of the competent authorities.

The competent supervisory authorities are listed on the following website:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

 

 

ARTICLE 7.                RECIPIENT AND PERSONS AUTHORIZED TO ACCESS THE USERS’ DATA

 

Only authorized persons working for the Data Controller [(including employees, volunteers, trainees etc.)] working for the Data Controller [and, in some cases, its subsidiaries], can access your personal data. The Data Controller makes its best effort to ensure that these groups of people remain as small as possible and maintain the confidentiality and security of User’s personal data.

 

The Data Controller also uses trusted service providers to carry out a set of operations on his behalf for hosting Stripe. The Data Controller can also use service providers in the tech industry, editors of specific tools integrated in the Platform for technical purposes.

    

The Data Controller only provides service providers with the information they need to perform the service and ask them not to use your personal data for any other purpose. The Data Controller does his best to ensure that all these trusted service providers only process the personal data on our documented instructions and provide sufficient guarantees, in particular in terms of confidentiality, expert knowledge, reliability and resources, to implement technical and organizational measures which will meet the requirements of the applicable legislation, including for the security of processing.

 

The Data Controller may be required to disclose or share your personal data to comply with a legal obligation, or to enforce or apply our terms of use/sale or any other conditions you have accepted; or to protect the rights, safety or property of American Society of Evidence-Based Policing, its customers or employees.

 

List of the main service providers:

 

Service Provider

Service

You can consult the privacy policy by clicking on the following link:

KIT UNITED

 

5 RUE DES ITALIENS

75009 Paris

France

HIVEBRITE solution

 

 

 https://hivebrite.io/privacy-policy

 

 

Child Safety Standards Policy

Child Safety Standards 

 

Any explicit content or child sexual abuse and exploitation (CSAE) is strongly prohibited on our application. 

Compliance with Child Safety laws & reporting 

 

Our app complies with applicable child safety laws and regulations. 

Our app ensures all content shared within the app is appropriate for a mixed audience, including children. User-generated content is moderated to prevent inappropriate material from being accessible.

Any CSAM (Child Safety Abuse Material) content will be automatically removed when flagged or reported through our moderation features or if we are directly contacted for this purpose. 

We will systematically take action to report confirmed CSAM content to the National Center for Missing and Exploited Children.
CSAM consists of any visual depiction, including but not limited to photos, videos and computer-generated imagery, involving the use of a minor engaging in sexually explicit conduct.

Child safety point of contact   

You can reach out to [email protected] if CSAM content is detected. 

Privacy and Data Protection

Our app is committed to protecting user data, especially for children under 13, in compliance with applicable regulations.

The privacy policy is displayed clearly and is accessible from the app settings and our website

All data is encrypted during transmission and stored securely.

Ads and Monetization

Our app does not include ads or monetized content. 

Transparency and Disclosures

Data safety: Detailed information is provided as per Google Play’s Data safety form.

Content ratings: IARC 3+, L, E, 3, 3, USK 0