PrivacyPortfolio, LLC
About Us
Our Policy
Your Choices
This privacy policy represents claims and rules pertaining to PrivacyPortfolio's privacy practices.
Rule:policyDescription
Value:This privacy policy represents claims and rules pertaining to PrivacyPortfolio's privacy practices.
Objective:Required to support Data Catalog Metadata Queries
Context:Any role or condition
Standard:Data Catalog Metadata Queries
Test:getPolicyDescription()
Evidence:online test results
Actionable rules derived from each claim
can be tested and evaluated by you.
Rule:testClaims
Value:[not set]
Objective:Allow consumers to test claims in policy.
Context:Any role or condition
Standard:[not set]
Test:uri testResults=testClaims()
Evidence:online test results

About Us

PrivacyPortfolio, LLC is a privacy rights consulting company in Alameda, CA, USA.
Rule:validatePublisher
Value:[not set]
Objective:verify identity of policy owner as organization or person
Context:Any role or condition
Standard:public authoritative document or record of identifying organization or person
Test:dataset proofOfIdentity=validatePublisher()
Evidence:online test results
PrivacyPortfolio empowers individuals to exercise their privacy rights, and to hold organizations accountable for enforcing their privacy policies and practices.
PrivacyPortfolio offers transparency into our privacy practices, by exposing how each claim can be verified by individual consumers.
Rule:verifyTransparency
Value:[not set]
Objective:Allow consumers to validate each claim.
Context:Any role or condition
Standard:Consumer can execute every test case.
Test:list testCases=listTestCases()
Evidence:online test results

Our Legitimate Interests

Our legitimate business interests allow us to process your personal information for the following purposes:
Rule:listOfLegitimateInterests
Value:[not set]
Objective:list each legitimate interest of publisher's need to use personal data
Context:Any role or condition
Standard:[not set]
Test:list legitimateInterests=listOfLegitimateInterests()
Evidence:online test results
1) To provide services in compliance with mutual agreements and applicable laws;
Rule:provideServices
Value:[not set]
Objective:Document where and when personal data is used to provide services.
Context:Subscriber
Standard:[not set]
Test:dataset ServiceDataMatrix=provideServices()
Evidence:online test results
2) To investigate complaints or concerns and ensure they are addressed appropriately to the satisfaction of all parties involved;
Rule:conductInvestigations
Value:[not set]
Objective:Document where and when personal data is used to conduct investigations.
Context:Subscriber
Standard:[not set]
Test:dataset ServiceDataMatrix=conductInvestigations()
Evidence:online test results
3) To provide an audit trail of PrivacyPortfolio's business activities, in the event of a dispute or deviation of our policies and practices.
Rule:conductAudits
Value:[not set]
Objective:Document where and when personal data is used to conduct audits.
Context:Subscriber
Standard:[not set]
Test:dataset ServiceDataMatrix=conductAudits()
Evidence:online test results

Our Contact Information

PrivacyPortfolio's preferred method of communication is through email as it provides a documented audit trail of communication exchanges.

For general inquiries:
(510) 330-8638
For security, privacy, or compliance:
(510) 330-8638
To request action or additional information
(510) 330-8638
To subscribe to sales and events information
(510) 330-8638

PrivacyPortfolio
311 Tideway Drive APT 107
Alameda,  CA  94501 US

Rule:getContactPoints
Value:[not set]
Objective:Provide all relevant contact points for communicating with the Publisher.
Context:Any role or condition
Standard:[not set]
Test:dataset contactPoints=getContactPoints()
Evidence:online test results

PrivacyPortfolio's alternative method of communication is by United States Postal Service, or by telephone if you need to communicate an urgent matter.

When you communicate with PrivacyPortfolio by means of our preferred methods of communication,
you are voluntarily sharing information with us,
which includes metadata provided by the media used,
as well as the information you explicitly provide to us.

Our Website

Now that you have read our Privacy Policy,
please learn how you can test our claims
by visiting our website:  PrivacyPortfolio - Home

Our Policy

Policy schema supports different policy types,
and includes Common Policy Markup Language rulesets.
Rule:policyType
Value:Privacy
Objective:Allow for a vocabulary markup of elements specific to policy type
Context:which policy type is represented by the Common Policy schema
Standard:W3C Common Policy
Test:getPolicyType()
Evidence:online test results

Policy schema supports multiple instances of a single policy type, distinguished by an unique name attribute.
Rule:policyName
Value:Privacy Policy | PrivacyPortfolio
Objective:Required to support Data Catalog Metadata Queries
Context:Any role or condition
Standard:Data Catalog Metadata Queries
Test:getPolicyName()
Evidence:online test results

Policy schema supports multiple versions,
using this string format for the version attribute:
"majorReleaseNumber(0-9).minorReleaseNumber(0-9)"
Rule:policyVersion
Value:1.2
Objective:Control and manage policy changes
Context:Version of this document
Standard:Users can access and use any version of a published policy
Test:getPolicyVersion()
Evidence:online test results

Policy schema provides an effectiveDate attribute to
support selection and enforcement of appropriate policies.
Rule:effectiveDate
Value:April 25, 2019
Objective:allow for evaluating the effective date of any version of any policy type
Context:effectiveDate of this policy
Standard:[not set]
Test:getEffectiveDate()
Evidence:online test results

Machine-Readable Version

PrivacyPortfolio provides our Privacy Policy
in xml format to support
automated policy management processes.
Rule:policyFormat
Value:xsd
Objective:support for different schema formats
Context:schema format of this policy
Standard:Schema formats may include XML Schemas, RDF and JSON-LD.
Test:getPolicyFormat()
Evidence:online test results

Policy Changes

PrivacyPortfolio will change this Policy periodically
based on changes to applicable laws and regulations
or changes in technology or our business operations.
Changes we make to the Policy in the future will:

1) change the policy version and effective date;
2) be posted as an update on our web page at privacyportfolio.com;
3) and if you have subscribed to changes in our policies or terms of service,
we will notify you directly according to your communication preferences.
Rule:policyChanges
Value:[not set]
Objective:list differences between two policy instances
Context:Subscriber
Standard:policy format must be the same for both policy instances to compare
Test:list = policyChanges(policy p1, policy p2)
Evidence:online test results

Policy Agreement Terms

A policy is not an agreement.
Common terms sourced from multiple policies
can be transformed into mutual agreements.
Rule:policyAgreementTerms
Value:[not set]
Objective:Establish that a policy is not an agreement, and describe how mutual agreements are formed from each party's policies.
Context:Many organizations think they can force consumers to implicitly agree with their policies.
Standard:Valid agreement must specify policy name, version, and effectiveDate in writing, and mutually signed by all parties.
Test:Scan all digital properties owned by PrivacyPortfolio for any text containing the phrase "agree with".
Evidence:online test results

Transformed policies can produce multiple agreements
according to the role contexts of each party.
Rule:listPolicyAgreementTermsByRole
Value:[not set]
Objective:List which mutual agreements can be transformed from a policy according to role.
Context:the role contexts of each party
Standard:Valid agreements must specify the role context of all parties.
Test:listPolicyAgreementTermsByRole(policy p1, role r1)
Evidence:online test results
RoleAgreements
CustomerTOS, NDA, DPA, SLA
VendorNDA, DPA, SLA
PartnerNDA, DPA
Subscriberconsent directives
Participantconsent directives

This policy has an owner who represents the legal, accountable party for the organization or person represented by the policy.
Rule:policyOwner
Value:Creator
Objective:Ensure ownership of policy by role
Context:the role contexts of each party
Standard:policy owner must be legally accountable
Test:listPolicyOwnerByRole()
Evidence:online test results
Role: CreatorPrivacyPortfolio, LLC
Role: AuthorPrivacyPortfolio, LLC
Role: PublisherPrivacyPortfolio, LLC
Each role is an entity defined by: schema.org

Your Choices

Personal Information is data attributed to you
 as a natural person.

Personally Identifiable Information is data
that can be used to identify you.

Sensitive Personal Data is data attributed to you that could cause harm to you if used by unauthorized parties for unauthorized purposes.
This category of data includes credentials,
identifiers such as Social Security numbers
 or financial account numbers,
and Protected Health Information,
which could be defined as any data
contained in an electronic healthcare record.
PrivacyPortfolio believes that individual persons,
(also known as "data subjects") should maintain
 an inventory of their personal information,
 along with authoritative provenance to establish
 a rightful claim of ownership to personal information.
PrivacyPortfolio collects personal data directly from individuals who voluntarily share it with us.
PrivacyPortfolio collects personal data indirectly from media metadata used to deliver the personal information.
PrivacyPortfolio collects personal data directly or indirectly from public directories where personal data is published.
PrivacyPortfolio prohibits the use of all cookies on its registered websites.
PrivacyPortfolio records in an audit log every time personal data is accessed.
Details of what personal data was accessed, when, and for what purpose, are available to individuals who can assert their ownership as the data subject.
PrivacyPortfolio does not intentionally transfer personal information about individual persons outside of the European Economic Area (“EEA”), Switzerland, or any country that requires legal protections for international data transfer.
PrivacyPortfolio stores personal information
until it reaches its maximum age threshold.
Our maximum age threshold for retaining personal information is one year.
PrivacyPortfolio conducts a Data Protection Impact Assessment annually
to re-certify our legitimate interests for storing and processing your personal information.
There may be exceptions to this policy and best practice for data governance, which includes legal obligations or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and most importantly, enabling you to enforce our rights and agreements.
PrivacyPortfolio takes appropriate security measures to protect personal information against loss, misuse, unauthorized access, alteration, disclosure or destruction.
We achieve these objectives by maintaining an isolated Personal Information Vault in which your personal data is stored in encrypted format, and protected by cryptographic access controls through an agent interface used as a proxy to represent your privacy rights as a data subject.
Whenever we access or process your personal information, it is performed through these interfaces and an audit log event is recorded to document each action.
Rule:getPersonalData
Value:[not set]
Objective:Provide all personal data collected so subscriber can compare it with their own personal data inventory.
Context:Subscriber
Standard:The dataset returned must include all data and attributes needed to validate publisher claims, including applicable laws, mutual agreements, company policy, and personal preferences.
Test:dataset personalData=getPersonalData()
Evidence:[not published]
Rule:getAccessLog
Value:[not set]
Objective:Provide all access records to subscriber's personal data so subscriber can evaluate claims of publisher.
Context:Subscriber
Standard:The dataset returned must include all data and attributes needed to validate publisher claims, including applicable laws, mutual agreements, company policy, and personal preferences.
Test:dataset accessLog=getAccessLog()
Evidence:[not published]

Your Rights

Your privacy rights are protected by privacy and data protection laws according to:

*where you reside
*where you engage in commerce
*where we collect or transfer personal data of residents
*which role identities your interactions are contextually associated with
*your personal preferences and explicit consent to process personal data
You have the right to file a formal complaint about PrivacyPortfolio's policies or practices to the appropriate authorities who are responsible for enforcing these legal protections.

You also have the right to use third-party advocates or agents to represent your privacy rights and register complaints on your behalf.

You have the right to access and modify any element of your personal data which is used by PrivacyPortfolio.

You have the right to request information about how your personal data is used by PrivacyPortfolio.
PrivacyPortfolio will respond within 30 days to all requests for information about how we use your personal data, including requests to return or delete your personal data.
Rule:privacyRights
Value:[not set]
Objective:Provide one default rule governing how the privacy rights of each individual data subject is protected, disseminated, and honored by PrivacyPortfolio.
Context:Any role or condition
Standard:[not set]
Test:list privacyRights=listPrivacyRights()
Evidence:online test results

Your Preferences

PrivacyPortfolio honors your preferences for how, when, and why we communicate and exchange information with you, such as fulfilling privacy requests. Your preferences are honored on the condition that they do not conflict with applicable law, or with our policies and practices, and to a reasonable extent, matching our own preferences.
Rule:subscriberPreferences
Value:[not set]
Objective:Provide methods for organizations and persons to register their communication preferences to send and receive notifications with the Publisher.
Context:Subscriber
Standard:[not set]
Test:ruleset subscriberPreferences=subscribe()
Evidence:online test results