Privacy Policy

Last Updated: July 1, 2022

We respect your concerns about privacy and value our relationship with you. Please read this Privacy Policy to understand our policies and practices regarding our collection, use, and disclosure of the information that you submit to us and that we collect from you through the Ohana Surf Project (“OSP”) website located at www.ohanasurfproject.com (the “Website”), and what rights you have in relation to your personal information. This Privacy Policy does not govern information you might provide through a channel other than this Website.

INFORMATION WE COLLECT

Information you submit to us

You may choose to provide personal information (for example, your name, address, e-mail address, telephone number) on our Website for various purposes, including the following.

• Bookings and product purchases: When you book lessons or equipment rentals on our Website or purchase products or services through our Website, you may provide us with information such as your name, birthdate, address, email address, phone number, credit card information, and medical conditions. We use this information to complete your booking or purchases event, contact you to confirm your booking and remind you about the upcoming lesson or rental, and to communicate with you about changes and updates regarding the lesson or rental. We also may use this information to communicate with you about other products or services we believe may be of interest to you.

• Contact Us: You can communicate with us through the “Contact Page” on our Website, which will ask you to provide your name and email address in connection with the comment or question you submit to us. We use this information to communicate with you about your comments or questions. We may also use the information you provide to communicate with you about topics we believe may be of interest to you.

• Other uses of information: We may use the personal information you provide on the Website for our internal purposes. These purposes include administration of the Website, market research, data analytics, and compliance with our legal obligations, policies, and procedures.

Automatically-collected information

We may collect other information about you that does not reveal your specific identity or does not directly relate to an identifiable individual, such as: (1) browser and device information; (2) information collected through cookies, pixel tags (also known as web beacons and clear GIFs), and other technologies; (3) demographic information; and (4) information that has been aggregated in a manner that it no longer reveals your specific identity (collectively, “Other Information”).

If we are required to treat Other Information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Policy.

Cookies

We use “cookies” on the website. A cookie is a small data file that the website writes to your hard drive when you visit. A cookie file can collection information such as your IP address, browser type, referring and exit pages, operating system, and dates/times of page views. A cookie cannot read data off your hard disk or read cookie files created by other sites.

We may use cookies to analyze visitor traffic patterns in order to improve visitor experience. We do not correlate this information with data about individual users.

A session ID cookie expires when you close your browser. We use session cookies to make it easier for you to navigate the Website. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to recall what information you have viewed in prior visits to the Website. You can remove persistent cookies by following directions provided through your Internet browser.

In addition, when visiting the Website for the first time, an option is presented allowing you to manage use of cookies.

The Website uses these cookies:

First Party Cookies

Cookie Name Domain Purpose
__gat .ohanasurfproject.com Google Analytics
__gid .ohanasurfproject.com Google Analytics
__ga .ohanasurfproject.com Google Analytics

Third Party Cookies

Cookie Name Domain Purpose
__gid .fareharbor.com Google Analytics
csrftoken fareharbor.com Security
fh-units-language fareharbor.com FareHarbor
__ga .fareharbor.com Google Analytics
fh-target-language fareharbor.com FareHarbor
mp_ .fareharbor.com FareHarbor
__stripe_mid .fareharbor.com Session cookie for Stripe (online payment processor used by FareHarbor)
__stripe_sid .fareharbor.com Session cookie for Stripe
optimizelyEndUserID .fareharbor.com Optimizely cookie to improve user experience and appearance of site
optimizelyPendingLogEvents .fareharbor.com Optimizely cookie to improve user experience and appearance of site
optimizelyBuckets .fareharbor.com Optimizely cookie to improve user experience and appearance of site
optimizelySegments .fareharbor.com Optimizely cookie to improve user experience and appearance of site
__stripe_sid .app.waiverforever.com Session cookie for Stripe
__stripe_mid .app.waiverforever.com Session cookie for Stripe
__gat .waiverforever.com Google Analytics
_hjincludedInSample .app.waiverforever.com Hot Jar cookie for performance
__gid .waiverforever.com Google Analytics
__ga .waiverforever.com Google Analytics

We do not currently respond to browser do-not-track signals.

Analytics

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Website and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. To view Google’s privacy policy, please click here.

Our vendors FareHarbor and WaiverForever also use Google Analytics. In addition, WaiverForever uses Hot Jar for analytics. To view Hot Jar’s privacy policy, please click here.

Children’s information

Our Website is directed at individuals over the age of 18 and is not directed at children under the age of 13. We will not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, do not provide personally identifiable information of any kind. Should you suspect that a child of whom you are the parent or legal guardian has provided us with personal information, please contact us at osp@ohanasurfproject.com and we will work with you to address the issue.

Your California Privacy Rights

Under California Civil Code Section 1798.83, California users are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. OSP does not sell or share your personal information with third party companies for their direct marketing purposes without your consent.

HOW WE USE YOUR INFORMATION

We use your personal information for legitimate business purposes, including:

• Providing the functionality of the Website and fulfilling your requests:
o To maintain the functionality of the Website.
o To respond to your inquiries and fulfill your requests when you contact us via one of our online contact forms.
o To send administrative information to you, such as information regarding our services and changes to our terms, conditions, and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with marketing materials
o To send you our newsletters and mailings related to our products and services that we think might be of interest to you.
o To fulfill your bookings and provide services, including the provision of lessons and equipment rentals

We will engage in this activity to perform our contractual obligations, with your consent, or where we have a legitimate interest.

• Aggregating and/or anonymizing personal information.
o We may combine your personal information with that of all or a particular group of Website users to prepare collective and anonymous profiles of site users and their interests or behaviors.

• Accomplishing our business purposes.
o For data analysis, for example, to improve the efficiency of the services we provide to our customers or to enhance, improve, or modify our current products and services.
o For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
o For fraud and security monitoring purposes, e.g., to detect and prevent cyberattacks or attempts to commit identity theft.
o To meet our legal and regulatory obligations.
o For identifying usage trends, for example, understanding which parts of our services are of most interest to users.
o For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

If we contact you using your personal information, it will be in the following ways:

Email: We only send emails to site visitors and users who sign up for one of our mailing lists or who agree to receive future communications from us. Our emails to you will contain clear information on how to unsubscribe from future communications. If you sign up for communications from us but then wish to unsubscribe, follow the unsubscribe instructions in the email you receive from us. Once we receive your unsubscribe request, we will cease our communication with you until and unless you re-subscribe for one of our mailing lists. You may also choose to stop receiving emails from us by notifying us at osp@ohanasurfproject.com at anytime. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

Telephone: We may also contact you by phone where you provide your phone number, in connection with a service request, comment, or inquiry you submit to us via the Website. If you do not wish to be contacted by phone, please indicate that to the individual who is calling you on our behalf, and we will remove your phone number from our contact list.

Information we transfer or share with others

Consent: We may share information you submit to us with your consent or at your direction

Service providers: We may share your information with service providers we have retained to perform services on our behalf, for example. We obligate these service providers to not use or disclose the information they receive from us except as necessary to perform services on our behalf or to comply with legal requirements. We use the services of FareHarbor, WaiverForever, Salesforce, Google, and DropBox. As such, we share your information with one or more of those vendors. For more information about the privacy policies of our vendors, please visit the following links:

• FareHarbor: fareharbor.com/legal/privacy/
• WaiverForever: www.waiverforever.com/privacy
• Salesforce: www.salesforce.com/company/privacy/
• Google: policies.google.com/privacy
• DropBox: www.dropbox.com/privacy

Compliance with law: In addition, we may disclose information about you (i) if we are required to do so by law; (ii) in response to a request from law enforcement authorities or other government officials; (iii) in connection with a judicial proceeding or to comply with a court order, law, or regulation applicable to us or the Website; or (iv) when we believe disclosure is necessary or appropriate to protect our property or assert our legal rights or to protect the property or safety of any other person.

Sale or business transaction: We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

Marketing choice and your rights to access and correct your personal information

We want to make sure that your personal information is accurate and up to date. You have the right to request access to and correction or deletion of your personal data, restrict processing concerning you and object to processing, as well as the right to data portability.

We will provide you with access to your personal information on request so you may view, update or correct your information. To protect your privacy and security, we will verify your identity before granting you access or enabling you to make corrections. You have the right to complain to a competent supervisory authority if you feel that we are not complying with our data protection obligations.

If you would like to access or correct your personal information or preferences, or have your information removed from our mailing list, please notify us at osp@ohanasurfproject.com.

HOW WE PROTECT YOUR INFORMATION

To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, we employ physical, technical, and administrative safeguards to protect against unauthorized disclosure, access to, or loss of the personal information we collect through the Website. All of our employees and any third parties we employ to process your personal information are obliged to respect its confidentiality. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the Website or to us, and you transmit such information at your own risk.

Changes to our privacy policy

We regularly review our privacy policy to ensure that it provides an appropriate level of protection for your personal information and we may make changes to our Privacy Policy to keep it current with industry standards. We will post the date of the most recent revisions on this page. Check this page to make sure that you are current and up-to-date on our privacy policy. Any changes will become effective when we post the revised Privacy Policy on the Website. Your use of the Website following these changes means that you accept the revised Privacy Policy.

How to contact us

Should you have any questions or concerns about our privacy policy, email osp@ohanasurfproject.com.