# Privacy Policy

We had to include this stuff. This document has to do with your computer talking to this website, not the Handshake network itself. When you talk to the Handshake network no single authority is in charge of it (not the authors of this website), and that your actions are public in a peer-to-peer network. Some of the items below were left over when there was a claim form for open source developers not on github or the PGP strong set.

Last Updated: 12/21/2019

#### HANDSHAKE.ORG’S PRIVACY POLICY (“Privacy Policy”)

Handshake Development Inc. (“Handshake,” “Us,” or “We”), recognizes that your privacy is important, and we want to be clear with you about our privacy policies. The present Privacy Policy describes how the Handshake.org website collects, uses and shares information collected from you through your use of Handshake’s websites (collectively referred to as the “Sites”) and the services offered through the Sites (the “Services”).

#### HOW HANDSHAKE.ORG COLLECTS INFORMATION AND THE TYPES OF INFORMATION COLLECTED

Any time you use Handshake.org’s Sites or Services, information is generated. Some of this information is considered “Personal Information,” meaning information that either directly identifies you individually (like email or billing information) or could reasonably be used to identify you in combination with other data. Other information is considered “Anonymous Information,” meaning information that does not directly identify, and cannot reasonably be linked with other data to identify you individually.

Handshake collects information from you in the following ways:

A. YOU PROVIDE THE INFORMATION TO US
When you visit or use our Sites or use our Services, you may provide us with information about yourself, your business, or your website. For example, if and when you set up a new Handshake account, you will be prompted by us to provide us with certain personal information in association with the freenode nickname, PGP key, or github account you are attempting to verify. You also understand that some of that non-personal information you provide to us may be aggregated and anonymized with other users to present nomination and voting results. If your account is verified then you will be able to submit information relating to the nomination and voting on behalf of yourself. You consent to the publication of the non-personal information or anonymous information you provide us about your choices and you understand that it may be published online and available to the public in an aggregated and anonymized format. Personal information we request from you may include:

- — Email address
- — GitHub user name
- — PGP key (public)
- — freenode nickname

If your account is verified up to a certain point, you will be required to provide certain tax information as stated in a 1099-MISC or a W8-BEN form including:

- — First and last name
- — Social security number/Foreign tax identification number/Employer Identification number/or tax identification number
- — Address
- — Telephone number

B. COLLECTED INFORMATION
While visiting the Handshake Sites or if you are using our Services, we may collect publicly available information from you through the use of cookies, web server logs, and other mechanisms with your consent. For example, when you visit a Site, we collect device identifiers (e.g., device model, operating system, browser version, and other data that may be used to identify a device), IP addresses, device configurations, browser history, information about Site usage, and geographic location data with your consent.

NOTE ON COOKIES AND SIMILAR TECHNOLOGY: Handshake uses cookies and web beacons to automatically collect information in connection with your use of the Sites and Services.

“Cookies” are small files that are placed on an individual’s computer when you interact with the Sites or Services. Cookies are often used to enable you to more easily communicate and interact with the Sites and Services. “Web beacons” (also known as “single-pixel” or “clear” GIFs) include electronic images embedded in the Site or in communications sent through the Services which are invisible to users. Web beacons can collect information, such as identifiers, time and date of access, and descriptions of the pages or communications in which the web beacons are embedded.

We may use cookies in communications sent through the Services for various purposes, including for example:

- — Saving user preferences;
- — Authentication;
- — Fraud prevention; and
- — Otherwise facilitating and enhancing interaction with the Sites

#### HOW HANDSHAKE USES AND SHARES PERSONAL INFORMATION WITH THIRD PARTIES

Handshake uses your personal information for a number of reasons including provisioning, maintaining and improving the Sites and Services, as well as for development of new services. For example, Handshake uses your information to administer your account, provide technical support and to communicate with you about your account. Handshake may also, with your consent, use your information to send you updates about the Handshake community.

Other than as described above, Handshake does not use your Personal Information, nor does it share your personal information with any third-parties, unless one of the following circumstances apply:

- — Handshake has your express consent; and
- — It is for Handshake’s internal use, research and product development;
- — External processing by our affiliates or other trusted third parties we use to support our business based on our instructions or other appropriate confidentiality and security measures (for example, companies that help Handshake improve its web site’s usability, verify your account, or understand customer interests); or
- — Detection, prevention or otherwise addressing fraud, security or other legal related issues.

Note that Handshake may share anonymously collected information with third parties. Handshake may also share Personal Information with companies, organizations or individuals outside of Handshake if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:

- — meet any applicable law, regulation, legal process or enforceable governmental request;
- — enforce applicable agreements or adherence to terms and conditions, including investigation of potential criminal law violations; and
- — protect against harm to the rights, property or safety of Handshake, our users, third parties or the public as required or permitted by law.

If Handshake is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy.

Handshake shall not sell nor license your Personal Information to a third party for that third party’s own direct marketing purposes.

#### YOUR PRIVACY CHOICES

TRACKING TECHNOLOGIES. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain cookies by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions. Note that if you disable or refuse cookies, some parts of the Sites may be inaccessible or not function properly.

SUBSCRIBING TO COMMUNICATIONS. If you wish to receive periodic newsletters, support Related Emails or other promotional communications from us, you may opt-in to receiving them at registration or by following the instructions included in each newsletter or by emailing support@handshake.org. In order to ensure the integrity, security and operation of our systems and networks, we do not allow you to unsubscribe from Service Notices unless you delete your account altogether.

#### YOUR RIGHT TO ACCESS AND CONTROL YOUR PERSONAL INFORMATION

You have the right to request that your personal information be corrected or deleted upon cancellation of your account. You have the right to request access to your personal information that We have collected at any time. Please contact customer support at support@handshake.org to request access to or deletion of your personal information or to request changes to the personal information associated with your account.

#### DATA RETENTION

We retain all personal information and data relating to your accounts indefinitely unless a data subject requests that their information be deleted.

#### CalOPPA STATEMENT

The State of California requires us to post specific language related to our privacy policy. By default, Handshake does not share your personal information with any third parties aside from the disclosures already made in this privacy policy. If you wish to inquire into how Handshake processes or collects personal information or how it shares personal information with third parties, you may contact:

Handshake Development, Inc.
1459 18th St, #316
San Francisco, CA 94107

#### SECURITY

Handshake has implemented policies that include administrative, technical, and physical safeguards designed to help protect Personal Information against unauthorized access, use, or disclosure. While Handshake strives to protect your privacy, because of multiple uncontrollable variables, including the inherent security flaws in the internet, Handshake cannot guarantee the security of any information you disclose to us and, as such, you agree that your disclosure of such information is at your own risk.

#### LEGAL BASIS FOR DATA PROCESSING

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal information is necessary for the performance of a contract to which the information subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal information is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal information may be necessary to protect the vital interests of the data subject or of another natural person. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal information. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

#### HOW WE TRANSFER INFORMATION COLLECTED INTERNATIONALLY

Handshake has established a global network presence and may maintain servers in many countries around the world, including the United States. You agree that we may process your personal information on a server located outside the country where you reside. You consent to the storage of personal information collected by Handshake on a server located in the United States. We will request your consent before we transfer your personal information outside of the country where the information is maintained.

#### COPPA DISCLOSURE - About Children’s Online Privacy

The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and services directed to, and which knowingly collect information from, children under the age of 13. Our online services are not directed to children under the age of 13, nor is information knowingly collected from them. For additional information on COPPA protections, please see the FTC website at: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online. Please contact us at support@handshake.org if you are aware of any uses of the Service by users under the age of 13.

#### PUBLIC FORUMS

Handshake may register and make chat rooms, forums, message boards, and/or news groups available to its users. Please note that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

#### NAME AND ADDRESS OF DATA PROTECTION OFFICER AND NAME AND ADDRESS OF CONTROLLER

Our current data protection officer can be reached at the following information below.

Handshake Development, Inc.
1459 18th St, #316
San Francisco CA 94107
Andrew Lee

#### CHANGES TO PRIVACY POLICY

Handshake reserves the right to modify this Privacy Policy from time to time at its own discretion and without any notice. We will post any changes to this Privacy Policy on this page and, if the changes are significant, we will provide a more prominent notice, which may include sending notice to you by email, posting notice of such changes on the footer of Handshake’s website, or by including a pop-up or link at the login page.

#### CONTACT INFORMATION

If you have any questions regarding this Privacy Policy, Handshake may be contacted through the following ways:

By email:
support@handshake.org

By mail:
Handshake Development
1459 18th St, #316
San Francisco CA 94107
Attn: General Counsel, Legal Department