Privacy Policy and Terms Of Use

Privacy Policy

Reclamo Online Privacy Notice for Users

At Pro Bono Net, Inc., we respect your privacy concerns. Please read this Notice to learn about:

  • The kinds of personal information we collect at our website, www.[TBD ].org, or our related mobile applications (a “Site”),
  • How we may use that information, and
  • Who we may share it with.

This Notice also describes how we protect your personal information, and how to contact us to learn more about our privacy practices.

Click on any topic:

What We Do With Your Information

The information you provide at a Site may be used to:

  • Create and manage your account
  • Communicate with you about your account, the Site or our services
  • Respond to your requests and questions
  • Customize your experience with the Site
  • Manage and improve the services we provide and how we communicate with you
  • Perform data analytics
  • Protect against fraud, and manage risk exposure
  • Develop new services
  • Meet and enforce all legal requirements, industry standards, and our own policies and terms, such as our Terms of Use

Information You Give Us

To create an account with Reclamo, we will ask for the following personal information:

  • Name
  • Date of birth and age
  • Gender
  • Contact information

The Reclamo platform allows you to save the progress of a claimant’s application to resume a later time only if the claimant agrees to allow you to save their information.

If you or your organization plan on contacting claimants using information provided in their applications, you must ask for the claimant’s consent to do so.

The information we collect from you regarding claimants is only used to help populate the New York State (“NYS”) Department of Labor (“DOL”) forms, and will not be used or sold by the Site in any other way. This data is subject to your data retention policy, and we may delete the data you provide us if not accessed within 180 days.

Information Collected Automatically

Our website collects information that helps us serve you and lets you use certain features of our services. To do this, we may use cookies, web server logs, web beacons, and JavaScript.

Cookies

Our website may use web, HTML5, and Flash cookies. These allow us to identify your browser and remember your information, settings, and your visits at the site. We may also use other types of local storage, such as browser- or plugin-based local storage. Most browsers give you the option of enabling, restricting, and disabling cookies. You can control Flash cookies by visiting Adobe’s FlashPlayer Settings or Settings Manager. Note: If you disable cookies, you will not be able to use all the features of our services. For example, cookies are required for the system to remember you for purposes of completing your DACA application forms and remember the information you provided before.

Our web server log may:
  • Collect information about your device, operating system, browser, access domain, and other system settings,
  • Identify your system’s language and your country and time zone,
  • Collect information about your current location;
  • Record the page that referred you to our site, your device’s IP address, and the pages you visit at our site.

To control which servers collect information, we may place tags (web beacons) on our pages. We also may send software instructions to your device that collect details of your interactions with our website, such as the kind of general information listed above.

Analytics

We may use analytic services from other companies, such as Google Analytics, to learn how visitors use our Sites. These services will know your IP address or similar identifiers for our mobile applications, and they share information with us about how you use our Sites.

Your usage information helps us to:

  • Troubleshoot any problems;
  • Understand usage of the Sites and improve them, and
  • Meet our legal duties and comply with policies and procedures.

Who May Have Access To Your Information

Service Providers

We use a number of outside service providers, such as cloud storage providers who store the information we collect, software developers we hire to debug or improve our program, providers who support certain features of our services that allow us to communicate with you (such as automated SMS text message providers, e-mail service providers, and live chat providers) and payment or credit card processors. These outside service providers may have limited access to your personal information to the extent necessary to provide their services. All of these service providers may only use or disclose your personal information to provide services to us or comply with legal requirements.

Researchers / Data Analysts

We may also share personal information for research, academic studies, data analysis, and reports. Information for these purposes is always aggregated and not personally identifiable. That means none of the information is linked to you or any other particular person. For example, the data we share may be used to say how many users (not the names of) live in New York. We may also share with others how many people (not who) visited our site.

We do not share information from:

  • Small categories of specific information that contain fewer than 5 people, or
  • Specific categories of personal information, such as names, Social Security numbers, login and access details.
Funders

We may share information about our users to our non-profit funders for research purposes. Information for these purposes is always aggregated and not personally identifiable.

We do not share information from:

  • Small categories of specific information that contain fewer than 5 people, or
  • Specific categories of personal information, such as names, Social Security numbers, login and access details.

When Information Sharing Is Required

For legal reasons

We may share your personal information if we have good reasons to believe we need to do so to:

  • Enforce our Terms of Service,
  • Protect our rights, operations, or users
  • Comply with applicable law, regulation or legal process, such as a court order or subpoena
  • Respond to an official request, subpoena, warrant or order from a government agency, such as law enforcement or an investigation of an illegal activity
  • Prevent physical, financial or other harm, injury or loss
If our organizational structure changes

If we sell or transfer some or all of our business or assets, such as during a reorganization, dissolution or liquidation, we may transfer your personal information to a third party. But that third party must agree to protect your personal information according to the terms of this Notice.

You May Change Your Information

You may change your personal information on the profile page for your account(s) at the site.

Deletion of Information

If you do not access your account for 180 days, your account and any information you have entered may be deleted. You may also request that we close your account by contacting us at support@immi.org using the e-mail address you used to register.

How We Protect Personal Information

We have administrative, software, and physical safeguards to protect the personal information you provide at our site against accidental, unauthorized, or illegal access, disclosure, destruction, loss, change, and other illegal use.

To protect Social Security numbers, we limit who may access SSNs, and only allow disclosure for legally allowed purposes.

The security of your information is important to us, but remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we make reasonable efforts to protect your information, we cannot guarantee its absolute security.

Links to Other Websites

Our site lists links to other websites that are not part of our organization. We list those links to make it easier for you to get information at their sites. We do not have control over the content or privacy policies at those sites. It’s a good idea to look at the Privacy Notices of those websites before you use them.

Privacy Policy Updates

If we change our privacy policies, we will post a notice on www.[TBD ].org. The date of the change will appear at the top of the Privacy Notice.

Terms Of Use

I.  General

Pro Bono Net, Inc. (PBN, for short) is a New York non-profit corporation that provides the website, www.[TBD] .org, and related mobile applications (each, a “Site”) as a free service to Representatives and organizations seeking to help workers fill out New York State (“NYS”) Department of Labor (“DOL”) forms.

These terms of use apply to LSOs and Representatives (as defined in Section II below).

When you use this Site you agree to all of the terms listed below. Please read them carefully. Also check these Terms of Use periodically because PBN updates them from time to time. All updates become effective when posted.

Using this Site means you agree to review and follow these:

  • LSO/Representatives Terms of Use,
  • All updates, and
  • Other policies and rules posted at this Site.
Together, these terms, updates, and other policies and rules form the complete agreement between you and PBN. The most recent version always supersedes any previous version, whether oral or written.


II.  Not-for-Profit Use by LSOs and Representatives

If not used for profit, this Site may be used by LSOs and Representatives to help individuals fill out DOL complaint forms.

LSO means:

  • An organization and their advocates giving not-for-profit or reduced fee legal assistance.
Representative means:
  • Lawyers or representatives and their staff in an LSO.

  1. No Lawyer-Client Relationship Exists between PBN and Claimants

  2. To use this site, you:
    • Agree to inform your clients that there is no lawyer-client relationship formed between PBN and claimants,
    • Acknowledge that the Reclamo platform is solely to be used to help LSOs and Representatives electronically populate DOL Complaint forms, and
    • Agree that neither PBN nor Reclamo will be named as a representative or as a party that helped the claimant, if required by the form.

  3. Claimant’s Data

  4. We will only save the claimant’s data if they agree at the beginning of the interview.

    If you or your organization plan on contacting claimants using information provided in their applications, you must affirmatively ask for their consent to do so before collecting this data.

    Please see our Privacy Policy for more requirements regarding data.

  5. LSO and Representatives Responsibilities

  6. When you use this Site, you agree that you alone are responsible for:
    • Protecting your client’s and your interests,
    • Using your own professional judgment to apply any information from this Site to the facts and circumstances of your client's case,
    • Verifying any information you get from this Site,
    • Personally assuring that your legal advice is based on accurate and complete information and research from any available sources.
    • Taking measures to address the security and privacy of any information you receive through this Site.

  7. Ethics Notice for LSOs and Representatives

  8. When you use this Site, you must follow all applicable ethical rules and standards, including for:
    • Conflicts of interest,
    • Advertising,
    • Client solicitation,
    • Unauthorized practice of law,
    • Privileged and confidential information, and
    • Misrepresentations of fact.

    PBN is not responsible for your compliance with these rules.


III.  LEGAL CLAIMS AND PROCEDURES

  1. Limited Liability

  2. BY YOUR USE OF THIS SITE, YOU AGREE TO WAIVE ANY AND ALL CLAIMS RELATING TO THE USE OF THE SITE OR ITS CONTENT, WHETHER SUCH CLAIMS ARE AGAINST PBN OR ANY OTHER PERSON WHO HAS SUPPLIED CONTENT TO THE SITE. UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY SHALL PBN OR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING, OR DELIVERING THE SITE BE LIABLE TO YOU OR ANY OTHER PERSON FOR ANY SPECIAL, DIRECT, INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY KIND WHATSOEVER (INCLUDING, WITHOUT LIMITATION, ATTORNEYS' FEES) IN ANY WAY DUE TO, RESULTING FROM, OR ARISING IN CONNECTION FROM, YOUR ACCESS TO, USE OF, OR INABILITY TO USE, THIS SITE. TO THE EXTENT THE FOREGOING LIMITATION OF LIABILITY IS PROHIBITED OR FAILS OF ITS ESSENTIAL PURPOSE, THE SOLE OBLIGATION OF PBN OR ANY OTHER PERSON WHO HAS SUPPLIED CONTENT TO THE SITE TO YOU FOR DAMAGES SHALL BE LIMITED TO $100.00.

  3. Indemnification

  4. You agree to indemnify and hold harmless PBN and any third party providing content to this Site, from any and all claims, losses, expenses, damages and costs, including but not limited to reasonable attorneys' fees, arising as a result of your use of this Site.

  5. Arbitration

  6. Any claims made related to this Site must be settled in New York by binding arbitration. The arbitration will be conducted in accordance with the then applicable Commercial Arbitration Rules of the American Arbitration Association. Each side will pay for its own costs, including attorney fees and costs.

    If you go to arbitration, your claim will be decided by one arbitrator who is knowledgeable about computer and Internet law.

    The arbitrator’s award will be binding and conclusive, and a judgment on any award may be entered in any court having jurisdiction. The arbitrator may not award punitive damages.

    Any claim made related to this Site will be arbitrated (or litigated, as the case may be) on an individual basis and shall not be consolidated with any claim of any other party whether through class action proceedings, class arbitration proceedings or otherwise.

  7. Jurisdiction

  8. These Terms of Use shall be governed by and construed in accordance with the laws of New York, without giving any effect to any principles of conflicts of law. You agree that any action at law or in equity arising out of or relating to these terms shall be filed only in the state or federal courts located in New York and you hereby consent to the personal jurisdiction of such courts for the purpose of litigating any action.

  9. Enforcing PBN's Rights

  10. When you use this Site, you agree that any use that violates these Terms of Use may cause irreparable injury to PBN. If you do not follow these terms, you agree that PBN will:

    • Have the right to non-monetary relief, including a court order requiring you to stop or to perform any relief a court may impose, and
    • Not have to post any bond or other security.


  11. Third Party Rights

  12. PBN and any contributor or other third party submitting materials to this Site have the right to enforce this agreement’s provisions for Disclaimer, Liability, Arbitration, and Indemnification against you on its own behalf.

  13. Severability

  14. If any part of these Terms of Use is found invalid or unenforceable, PBN and you agree that:

    • All other parts of this agreement are valid,
    • The intended meaning of the invalidated part will be replaced with language that closely matches PBN’s original intent, and
    • This agreement remains valid.

    Even if a term of this agreement goes unenforced, PBN does not waive any part of this agreement, unless it does so in writing.

  15. Notification of Alleged Copyright Infringement

  16. PBN reserves the rights to remove any content that allegedly infringes a third party's copyright or otherwise violates the rights of any third party, or for any reason whatsoever, and to prohibit further use of this Site by the individuals responsible for said infringement or violation. PBN also reserves the rights to pursue any party that submits an erroneous declaration. If you believe that any content appears on this Site in violation of your copyright or other proprietary rights, you should send a notice to PBN by first-class mail, return receipt requested, at the following address: immi , c/o Pro Bono Net, Inc., 151 West 30th Street, 6th Floor, New York, NY 10001. Such notice should include the following:

    • Identification of the copyrighted work claimed to have been infringed.
    • Identification of the material that is claimed to be infringing or to be the subject of infringing activity. Include information reasonably sufficient to permit PBN to locate the material.
    • Information reasonably sufficient to permit PBN to contact you, such as an address, telephone number, and, if available, an e-mail address.
    • The signature of the complaining party.
    • Include the following statement: "I have a good faith belief that use of the copyrighted materials described above as allegedly infringing is not authorized by the copyright owner, its agent, or the law."
    • Include the following statement: "I swear, under penalty of perjury, that the information in the notification is accurate and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed."

  17. Integration

  18. The version of these Terms of Use currently available at this Site, incorporating by reference any supplemental rules or terms posted on this Site, constitutes the complete statement of the agreement between you and PBN. That version supersedes and merges all prior proposals, understandings, and all other agreements, oral and written, between the parties relating to the subject matter of the agreement.

  19. Modification to Terms of Use

  20. Updated versions of the Terms of Use will and are effective immediately. Your continued use of this Site after any update constitutes your agreement to be bound by the updated Terms of Use. You are responsible for regularly reviewing the Terms of Use.


IV.  Other Terms

  1. User information

  2. To use certain parts of this Site, you must provide your registration information, including a username and password. The information you provide must be correct and complete, and you must update it if any of that information changes.
    To use this Site, you must agree to:
    • Use your chosen username and password when you access the Site,
    • Not let anyone else use your username or password to access this Site,
    • Be liable for anyone who accesses the Site with your user information, and
    • Protect your user information so that others cannot use it.

  3. Protect Your Password

  4. To protect your information, you should not use your name, birthday, address, street name, Social Security number, alien registration number, driver’s license number, a single word, or other information that is easy to guess. A strong password should include a combination of capital and lowercase letters, numbers, and symbols and should be at least 8 characters long. If you suspect someone is using your login information, contact us right away at: support@immi.org.

  5. No Illegal Activity

  6. PBN may investigate complaints and reported violations. If we suspect illegal or inappropriate activity, we may report it to law enforcement officials, regulators, or other parties. We may disclose user information of anyone or any entity involved in that activity to the extent necessary, including: user profiles, e-mail addresses, usage history, submitted or uploaded materials, IP addresses, and traffic information. If possible, we will take reasonable steps to minimize the disclosure of confidential information of users who are not the target of the investigations, such as by redacting confidential information.

    You must not use this Site in any way that would be considered as illegal under New York law, U.S. law, or the laws of your state.

    Do not use this Site to:
    • Upload content that is illegal, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, invasive of someone’s privacy, hateful, or racially, ethnically objectionable, or wrongful in some other way,
    • Harm a child in any way,
    • Misrepresent your affiliation with a person or agency or impersonate a person or agency, including PBN or its staff,
    • Upload content that you do not have a right to transmit, including information from fiduciary relationships, such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements,
    • Upload content that infringes, misappropriates, or in any way violates a party’s patent, trademark, trade secret, copyright or other proprietary rights,
    • Stalk or harass someone, or
    • Use any function of this Site to collect or store personal data about other users unless PBN and the user(s) have authorized you to do so.

  7. PBN’s Ownership Rights

  8. This Site is protected by copyrights, trademarks, trade dress, service marks, patents and other proprietary rights and laws. PBN alone owns its copyrights to this Site’s layout, graphics, navigation design, source code, the collective and compiled copyrights in its databases, and all other content created by PBN employees, contractors, consultants, and contributors to this Site.

    You may not use or alter any of the information or content on this Site in any way, except that you may use the Site and print copies of it for personal, non-commercial use.

    Any print-outs from this Site must retain all copyright, trademark and other proprietary notices.

    You may not use PBN’s trademarks, service marks, or trade dress in any way, including in:
    • Services or products not owned by PBN,
    • A way that causes confusion or implies that PBN sponsors, endorses, or is connected to your own activities, products, or services,
    • Hidden or embedded text in web pages, or
    • A way that is critical of PBN or this Site.

  9. Follow PBN's Rules

  10. To use this Site you must follow these Terms unless you get PBN’s express written permission to do otherwise.

    Do not:
    • Upload unsolicited or unauthorized advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes, or other form of solicitation, except in areas designated for that purpose,
    • Upload material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software, hardware, or telecommunications equipment,
    • Interfere with this Site or the servers and networks connected to this Site, or
    • Disobey any requirement, procedure, policy or regulation of a network connected to this Site.

    You must not use any part of this Site, its content, or its underlying programs to:

    • Decompile, extract or disassemble our source code,
    • Copy, change, reproduce, republish, distribute, display, or transmit for commercial, non-profit or public purposes any part of this Site, its content or its software, except as allowed by other terms of this agreement,
    • Rent, lease, loan, sell, sublicense, or create derivative works from this Site, except as allowed by the terms of this agreement,
    • Use software or other methods to monitor or copy our Site or software,
    • Determine the Site architecture or extract information about usage, users, or their identities, or
    • Use, export, or re-export any part of this Site or its content in violation of U.S. export control laws.

    You must not use any material owned by PBN or licensed to PBN by a third party for any use, especially not for any commercial use. This includes:

    • Text, forms, documents, images, graphics, logos, or button icons,
    • Any other material or information you get from a PBN’s contributors,
    • Other content or copyright material owned by PBN or a PBN contributor, and
    • Any PBN trademark, service mark, or logo.


  11. Communications with PBN

  12. You may communicate with PBN by e-mail, our support form, or through the live chat feature for questions about PBN’s service or for limited technical support.

    If you send us an e-mail or a message through the live chat system, please be advised that the Internet is not a secure method of transmitting information. We shall have no liability for any loss or damage that results from interception and/or unauthorized use by third parties of any information you send by e-mail or live chat. For information regarding our use of your e-mail address and other personal information, please review our privacy policy.

  13. Privacy

  14. To use this Site you must agree to PBN’s privacy policy.

  15. Links

    1. Links to other websites

    2. This Site may list links to other websites. We do this for your convenience only. When you click on a link to other websites, you leave this Site. Those links are not a recommendation or approval of those sites or their owners and those websites are not under PBN’s control. We are not responsible for those websites, the information, services or products they may offer, or any loss or damage you may have at those sites.

    3. Links to this Site

    4. You may not link to this Site from another website for commercial purposes. Any links to this Site from other sites do not imply any affiliation between PBN and those other sites.

  16. Disclaimer

  17. PBN does not guarantee or warrant this Site or its content to be always available, correct, up-to-date, reliable, free of viruses or other defects, or that any problems or inaccuracies will be corrected.

    PBN is not responsible for any loss, injury, claim, liability, or damage related to:

    • The hardware or software you use to access this Site,
    • Your use of this Site or its content for any purpose, including related to legal advice,
    • Any errors or omissions in the content at this Site or other websites you are directed to from this Site, or
    • The unavailability of this Site or its content.

    PBN makes no guarantee that any material on this Site is
    • Suitable for any special purpose, or
    • Free of any claim of ownership by a third party.

    PBN DISCLAIMS ALL WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION THE WARRANTIES OF MERCHANTABILITY, TITLE, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.