HandsOn Connect Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

Effective Date: November 1, 2013

Our Commitment To Privacy

Thank you for visiting HandsOnConnect.org (“Site”) or the HandsOn Connect Application (“App”) which is a service in partnership with Points of Light (“POL”). Your privacy is important to us. Our ongoing commitment to the protection of your privacy is essential to maintaining the relationship of trust that exists between HandsOn Connect and all of our partners, clients, volunteers, volunteers with a personalized account, readers of our newsletters or other users of HandsOn Connect or visitors to this Web site. This Privacy Policy details certain policies implemented throughout HandsOn Connect and POL governing our online information security practices.

User Consent

By submitting Information through our Site or App and/or our Web Services on Partner sites, you agree to be bound contractually by the terms of this Privacy Policy and you expressly consent to the processing of your Information according to this Privacy Policy and you agree to the HandsOn Connect Terms of Service (the “Terms of Service”).

By using our Site, App or service, you consent to our Privacy Policy. If you don’t agree, please don’t use our Site, App or Service.

Privacy Policy Updates and Modifications

We reserve the right to modify this Privacy Policy at any time, upon prior notice to you by email or posted on our notifications board on our help desk, and by thereafter posting amended terms on this Site. Your continued use after such notice, indicates your acceptance of the amended Privacy Policy. You should check this Privacy Policy periodically for modifications by referencing the Effective Date posted above.

The Information We Collect

You may have accessed HandsOn Connect via the HandsOn Connect Application or directly by visiting our Site or App, the home page of which is located at www.HandsOn Connect.org, or through the Web site of one of our third-party partners with whom we have teamed to provide volunteering services, such as (a) a HandsOn Connect co-branding partner; or (b) a corporate partner (collectively, “Partners”). This notice applies to all information you submit to HandsOn Connect through the HandsOn Connect Site or App. Please note that we cannot be responsible for the information you submit directly to third parties, including our Partners, who may have their own posted policies regarding the collection and use of your information. We urge you to review the policies of our Partners through whom you may access our services.

Personal Information

You can access many sections of our Site or App without revealing any personally identifiable information about yourself. We will not collect any personally identifiable information from you unless you voluntarily submit such information to us. Therefore, if you do not want us to obtain any personally identifiable information about you, do not voluntarily submit such information to us. However, in certain sections of this Site or App, we may invite you to log in through a third party social networking service, contact us with questions or comments, volunteer, request to build applications and submit product feedback. Due to the nature of some of these activities, we may collect personally identifiable information that you submit such as your login credentials, name, email address, zip or postal code, organization name, and organization website. We may also collect additional personally identifiable information that you voluntarily transmit with your communications to us.

In no way limiting the generality of the foregoing, you may have the option to submit the following types of information on our Site or App, which may or may not be personally identifiable information, and that may change from time to time:

For Newsletter and Webinar Subscribers:

• First and Last Name
• Email address

For volunteers without a personal HandsOn Connect account who have accessed HandsOn Connect through HandsOnConnect.org or a Partner’s Web site:

• First and Last Name
• Email address
• Telephone number
• Address, City and State (optional)
• Zip Code
• Comments about volunteer opportunity (optional)
• Other categories of information required or requested by an Agency to register for a particular volunteer opportunity.

For volunteers with a personal HandsOn Connect account who have accessed HandsOn Connect through HandsOnConnect.org or a Partner’s Web site:

• First and Last Name
• Email address
• Telephone number
• Address, City and State (optional)
• Zip Code
• Your skills profile
• Comments about volunteer opportunity (optional)
• Username and Password
• Referral history
• Customized email preferences (optional)
• Feedback and comments
• Other categories of information required or requested by an Agency to register for a particular volunteer opportunity.

For Nonprofit Member Agencies:

• Administrator Information – First and Last Name; Email; Telephone Number; Zip Code; Username and Password. Address; City; State (optional)
• Agency Information – Agency Name; Contact Information (Contact Title, First and Last Name, Telephone Number, Address, City, State, Zip Code, Email); Description Of Services; Mission Statement; Tax ID/EIN; Affiliations; Volunteer Type Category. Web site Address;
• Volunteer Opportunity Information – Opportunity Title; Contact Email; Description; Volunteer Type; Location Information (either Street Location or “Virtual” Designation). Required Skills; Date; Time; Commitment Information; Volunteer Age; Group Size (optional).
• Feedback and comments

The Site or App may track the total number of visitors to our Site or App, the number of visitors to each page of our Site or App, the aggregate number of users that click on a certain volunteer listing, search terms, IP address, browser type, the aggregate number of volunteers from particular cities, states or provinces, zip or postal codes and other aggregate and anonymous information, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in anonymous and aggregate form only and it will not contain personally identifiable information. For example, we may use this aggregate information to provide volunteer information in your area.

If you decide to use a social networking service to sign in, you are using other services like Facebook Connect. These services give us a token that allows social features on the site, and this token is stored on our third party hosting provider’s servers. The respective sign-in services have privacy settings and policies that let you control your preferences. By default, those services use a cookie that stores your login ID (but not your password) to make it easier for this Site or App to recognize when you return to the Site or App. You can remove or block this cookie using the settings in your browser if you want to disable this feature.

When you are signed in to the Site or App, you may send messages, “like” an activity and transmit information through various channels. We collect information from these activities through this Site or App so that we can provide you with our service and offer personalized features, such as your activity page. In most cases, we retain this information so that, for instance, you can return to view activities you “like” or to easily see your friend list. When you update information, we usually keep a backup copy of the prior version for a reasonable period of time to enable us to revert to the prior version of that information. If you decide you don’t want to have your activity page on the Site or App, and you’re OK with having all history permanently removed, you’ll need to fill out and submit the Delete Account form.

Use of Information

General, Site or App Improvement and Personalization

In general, we use the personally identifiable information collected on our Site or App to help us understand who uses our Site or App and how it is used, to personalize your experience, to assist you in using our Site or App and to improve our Site or App. We also use the non-personally identifiable information collected automatically by our servers primarily to help us administer and improve our Site or App.

We reserve the right to use your Information to send you e-mails regarding system downtime and/or the right to make changes to this Privacy Policy or the Terms of Service, and you are not permitted to opt out of receiving these e-mail messages.

We do not sell or rent our volunteer, administrator, nonprofit, or general newsletter email addresses to outside parties.

For Newsletter or Webinar Subscribers:

If you become a registered member of our Site or App, we may use your information to send you a welcoming email that may confirm your user name and password and offering you the opportunity to “opt-in” to receive further communications from us. If you agree to “opt-in” we may send you electronic newsletters, contact you about online services, related information and news items that may be of interest to you, such as product enhancements, tool upgrades, volunteer project or other civic engagement recommendations, or membership news and provide you with targeted feedback. If you decide you no longer want to receive these communications from us, we will provide you with an option to “opt-out” and change your preferences.

For volunteers without a personal HandsOn Connect account who have accessed HandsOn Connect through HandsOnConnect.org or a Partner’s Web site:

To the extent that you have provided any Information to us through our Web site regarding volunteer opportunities associated with one of our Partners, we may share your Information and referral history with the applicable Partner. Each of our Partners has its own policies regarding the collection and use of personal information, and HandsOn Connect is not responsible for their use of your Information. Furthermore, our Partners may collect additional information from you, independent of HandsOn Connect.org, in connection with the volunteer services.

For volunteers with a personal HandsOn Connect account who have accessed HandsOn Connect through HandsOnConnect.org or a Partner’s Web site:

If you indicate to us that you are interested in creating a personalized account, the information we gather from you will be used to permit you to: access the account, customize outbound email services, review your referral history and/or create a skills profile that can be searched in response to inquiries made by Agencies using HandsOn Connect’s Services.

Please be aware that, to the extent required to allow you to sign up for a volunteer opportunity (at your request), we may share your Contact and Skills Profile Information with other volunteers, Nonprofit Member Agencies, or other Partners, as applicable.

If you indicate to us that you are interested in particular volunteer opportunities and provide us with your Information – including your skills profile – either through www.HandsOn Connect.org or a Partner’s Web site, we will forward your Information to the Agency that is hosting that opportunity so that the Agency can contact you regarding your potential involvement, and, if the particular Agency (including an Agency that is a Partner) has a regional or national office or is closely affiliated with or a member of a related Agency (each, an “Affiliate”), then we may also share your Information with the applicable Affiliate.

If you indicate to us that you are interested in offering your services in Disaster and provide us with your Information – including your skills profile – either through www.HandsOn Connect.org or a Partner’s Web site, we will enable Agencies responding to that disaster to contact you blindly regarding your potential involvement. It is up to you to decide whether or not to respond.

For volunteers with a personal HandsOn Connect account who have accessed HandsOn Connect through their employer’s Web site:

We may share your Information with your employer so that your employer may log the number of hours you have volunteered during a specified period of time (“Hours”). In some instances, your employer may share your Information with third-party service providers to help your employer process data regarding your Hours. Your employer has its own policies regarding the use of your Information, and HandsOn Connect is not responsible for your employer’s use of your Information. Furthermore, your employer may collect additional information from you, independent of HandsOn Connect.org, in connection with the volunteer services.

For Nonprofit Member Agencies:

If you submit Information to us as an Agency, then, subject to the terms and conditions as a nonprofit member of HandsOn Connect, your Information (excluding your EIN number) will be accessible by anyone who accesses HandsOn Connect. In addition, we may share your Information, including your EIN number, with selected Partners in order to verify your Agency’s identity and tax status.

Agencies who receive email addresses from potential volunteer signups are strongly encouraged to adopt privacy standards similar to those of HandsOn Connect. Each such Agency, however, has its own policies regarding collection and use of personal information and we are not responsible for their use of your Information. Inappropriate use of personal information received from HandsOn Connect may jeopardize nonprofit membership with HandsOn Connect. HandsOn Connect reserves the right to determine, in its discretion, what constitutes inappropriate use of this information. For more about an Agency’s policy, please contact them directly using the contact information posted for that Agency on our Web site.

If you submit Information to us as an Agency, then, subject to the terms and conditions as a nonprofit member of HandsOn Connect, your Information (excluding your EIN number) will be accessible by anyone who accesses HandsOn Connect. In addition, we may share your Information, including your EIN number, with selected Partners in order to verify your Agency’s identity and tax status.

Please note that any feedback or comments provided by you on the Web site may be generally accessible by any visitor to the Web site. Therefore, please take care when posting feedback or comments to the site, as you will forfeit the privacy of that information.

Use of System Information

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the web pages you request) can be sent to you. We will not use your IP address to attempt to identify your personal information.

A Referrer is the information passed along by a web browser that references the Web URL you linked from, and is automatically collected by our web server as “traffic data”. We reserve the right to use this information to identify broad demographic trends that may be used to provide information tailored to your interests. You will not be personally identified from this information.

System information that we collect as part of “traffic data” includes time, the type of web browser being used, the operating system/platform, and CPU speed. This information is sent automatically by your web browser when you are connected to a web site. We reserve the right to use this information for purposes of identifying broad demographic trends and may be used to provide information appropriate for your computer system. You will not be personally identified from this information.

Information Sharing

You may share content from this Site or App with your friends using social networking services and such social networking services may collect and use your information as set forth in their own privacy policies. We may provide the aggregate information that we collect to our third party partners that provide volunteer opportunities on this Site or App but such information will not personally identify you. We may provide your personally identifiable information and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our Site or App and related services to you solely as necessary to provide our Site or App and services to you. We may disclose your personally identifiable information when we reasonably believe we are required to do so by law, or when we deem it appropriate or necessary to provide such information to law enforcement authorities. We will not sell, rent, trade or transfer your personally identifiable information to any company or organization except that we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which HandsOn Connect or POL participates or to a non-profit assignee.

Cookies

Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. Most browsers are initially set up to accept cookies. If you prefer, you can set your browser to refuse cookies. However, you may not be able to take full advantage of this Website if you do so. We reserve the right to use cookies to collect demographic and profile data for purposes of delivering content specific to your interests. Advertisers that display ads on our Site or App may also use cookies; however, we do not have access to the information obtained from cookies issued from other sites.

Advertisements that appear on this Site or App or in connection with the software services provided in connection therewith are sometimes delivered directly to users by third-party advertisers, who automatically receive your IP address at that time. They may also download cookies to your computer or use similar techniques to gather information about you. These techniques enable the third-party advertiser to recognize your computer each time they send you an advertisement so that they may track the effectiveness of their advertisements and customize the advertising content. We do not have access to or control of any of the foregoing technologies that may be placed on our Site or App or used in connection with our software services offered through our Site or App by such third-party advertisers. However, third-party advertisers do not have access to your personally identifiable information unless you choose to share it with them via your own personal computer settings. This Privacy Policy covers our use of cookies and similar technologies on our Site or App and does not pertain to the use of cookies or other similar tracking technologies by any third-party advertisers.

Your Choices; How You Can Review or Correct Your Information

You do not need to log into a third party social networking service to use this Site or App. You may use HandsOn Connect without providing a user name or any other personal information. You can delete cookies stored on your computer by following the instructions for deleting cookies in your browser.

If you are a nonprofit member or volunteer with a personal HandsOn Connect account (either through the Site or App or a Partner’s Web site) you may review and make changes to all of your Information that we collect and maintain online by simply inputting your username and password where indicated on the Web site. If you are a volunteer with a personal HandsOn Connect account, once you login in, you may make any changes or correct factual errors in your account by changing the information on your login page. This option is available 24 hours a day to better safeguard your Information, subject to downtime for standard maintenance and support. You do not need to contact us to access your record or to make any changes. If you have problems changing your Information, please contact Community Services at support@HandsOnConnect.org.

For Nonprofit or Other Volunteer Agencies

If you are an Agency administrator, you may make any changes or correct factual errors in your administrator, organization, and opportunity information 24 hours a day. We use this procedure to better safeguard your Information. You do not need to contact us to access your record or to make any changes. If you have problems changing your Agency’s Information, please contact Community Services at support@HandsOnConnect.org If you are a nonprofit member or volunteer with an account and would like to have your Information deleted from the site, you may do so by contacting us at support@HandsOnConnect.org

Links to Third Party Sites

The Site or App may provide links to other Web sites or resources over which HandsOn Connect does not have control (“External Web Sites”). Such links do not constitute an endorsement by HandsOn Connect of those External Web Sites. You acknowledge that HandsOn Connect is providing these links to you only as a convenience, and further agree that HandsOn Connect is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Children’s Privacy

HandsOn Connect recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site or App is not intended for children under the age of 13. HandsOn Connect does not target this Site or App to children under 13. HandsOn Connect does not knowingly collect personally identifiable information from children under the age of 13.

Security; No Liability for Acts of Third Parties

We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. HandsOn Connect may use password protection and other security measures to help prevent unauthorized access to your personally identifiable information.

Unfortunately, no data transmission over the Internet can be guaranteed 100% secure. As a result, while we strive to protect your personal information, WE CANNOT ENSURE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK.

Although we will use reasonable efforts to safeguard the confidentiality of your personally identifiable information (including credit card information, if applicable), transmissions made by means of the Internet cannot be made absolutely secure. We will have no liability for disclosure of information due to errors in transmission or unauthorized acts of third parties. In addition, we will release specific information about you to comply with any valid legal process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if there is an attempted breach of security or a physical threat to you or others.

Please note that if you give out personally identifiable information online, such information can be collected and used by third parties. Although we strive to protect our users’ privacy, we cannot guarantee the security of information you post on this Site or App. You disclose such information at your own risk.

Users Outside of the United States

Our computer systems and some of the computer systems of our third party service providers are currently based in the United States, so your personal data will be processed by us in the United States where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. As a visitor from outside the United States, by using the Site or App you agree to this Privacy Policy and you consent to the transfer of all such information to the United States, which may not offer an equivalent level of protection of that required in the European Union or certain other countries, and to the processing of that information as described in this Privacy Policy.

GDPR and HandsOn Connect

On May 25, 2018, the EU General Data Protection Regulation (GDPR) will become effective. This document provides some details on the steps we have taken to comply.

For the effects of GDPR, HandsOn Connect is the processor and our clients that use our products and services, such as the App, are the controllers.

Your Choices

Right to Review and Rectify Your Personal Data.

Customers can request a history of their Account Information.  For support information, a customer can update most of your Account Information by logging on to your account. However, if additional assistance is required to change or delete inaccuracies within other Personal Data or would like to know what other information about you was collected, please contact us at dataprotection@handsonconnect.org.

Right to Remove or Withdraw Consent

You have the right to withdraw consent where such consent is required to share or use data and you may request that we delete your Personal Data.

If you would like to delete data from our App, please contact the HandsOn Connect customer using our App and that is holding your data, and providing the services to you.

If you receive newsletter or marketing communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings. You can delete your Account Information by submitting a request to the HandsOn Connect customer that holds your data.  Each customer will have their own procedure. However, since your Account Information and Account History is required for us to provide the Services to you, deleting it will also terminate your access to the services. Deleting your Personal Data does not mean that all of it will be removed. We or our customer take steps to delete Personal Data is no longer necessary in relation to providing the Services by deleting it within 120 days of your terminating your account or if the account remains unused for more than one year.  We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our customers to retain some information in connection with our obligation to provide the Services. We may de-identify and anonymize some data for purposes of retaining it.

Data Portability

If you would like us to transmit your Personal Data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.

Right to Redress

If you are a subject of the European Union or European Economic Area and Switzerland and you believe we have violated any data protection laws that apply to you, you have a right to file a complaint.  Please contact the Information Commissioner’s Office in the United Kingdom.

Processing End User Data for Customers

Our services may involve the processing of Personal Data on behalf of our customers.  When we do so, we are acting as processors for the controllers of such data. As such, we take steps to ensure that Personal Data subject to GDPR is processed in accordance with controller instructions and GDPR such as entering into a Data Processing Addendum incorporating EU Standard Contractual Clauses governing the processing, transmission, and use of such End User Personal Data.  If you wish to exercise your data subject rights to review, rectify, delete or port your End User Personal Data please contact the controller to make such request. If you make the request to us, we will work with the controller to process and evaluate such request to confirm whether deletion is required by GDPR.

Transnational Transfer of Data

If you are providing your Personal Data to us directly to use our Site or App, we will transmit your data, including your Personal Data, to the United States in order to fulfill our contractual obligations to you.

Data Sub-processors used by HandsOn Connect

We maintain the following list of sub-processors:

• Salesforce: Customer Relationship Management. United States.
• Microsoft Azure: Application hosting. United States.
• QuickBooks: Customer invoicing, payment processing and credit card processing. United States.
• Google Analytics: Application analytics. United States.
• Jira: Development issue tracking and reports. United States.
• Raygun: Error, Crash & Performance Monitoring For Web & Mobile Apps. United States.
• Logentries: Application Logs. United States.
• Zendesk: Customer support and documentation. United States.
• Hootsuite: Social media management. United States.
• All for Good (Points of Light): Volunteer opportunity aggregator and search. United States.
• Cabot Volunteer Rewards: Opt-in rewards program for volunteers.  United States.
• WPEngine host. United States.

Controllers may share your data with other sub-processors.  Make sure to check with them for more information.

We and our third-party service providers may collect certain tracking information about your use of our Site and Service. For example, we collect;

• Log information (including your IP address, browser type, Internet service provider, referring and exit pages, operating system, dates/time of access, and related data)
• Information collected by cookies and tracking pixels (as discussed earlier)
• Web beacons (also called “Internet tags” or “clear gifs”; used to count visitors to our Site and which pages were viewed and links clicked)
• Embedded scripts (code temporarily downloaded onto your device to collect information about your interactions with the Service and thereafter deleted or deactivated)

Notifications and Objections

Notifications and objections can be sent to dataprotection@handsonconnect.org.

More Information

If you have any questions regarding this Privacy Policy please contact us via this form: https://www.handsonconnect.org/contact.

Third-party Access and Use

We, or our Partners, may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to our Site or App and the services we offer, such as hosting and maintaining our message boards or chat rooms and developing applications for our Website and e-mail services. These Outside Contractors may sometimes have limited access to information collected on our Website, including your personally identifiable information, in the course of providing products or services to us. Access to your personally identifiable information by these Outside Contractors is limited to the information reasonably necessary in order for the Outside Contractors to perform their limited function for us. We also require that these Outside Contractors (i) protect the privacy of your personally identifiable information in a manner consistent with this Privacy Policy, and (ii) not use or disclose your personally identifiable information for any purpose other than providing us with the products or services for which we contracted

DMCA Notice

If you have a copyright infringement claim regarding any materials posted on our Site or App, you are directed to file a copyright infringement notice with us by sending a written communication that includes substantially the following information (please consult your attorney or review § 512(c)(3) of the United States Copyright Act to confirm the accuracy of these requirements):

(i) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

(ii) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site.

(iii) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit us to locate the material.

(iv) Information reasonably sufficient to permit us to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted.

(v) A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.

(vi) A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Such written notice should be sent to our designated agent as follows:

DMCA Complaints
HandsOn Connect Cloud Solutions
Chief Administrative Officer
12157 W Linebaugh Ave, #332
Tampa FL 33626

Email: dataprotection@handsonconnect.org

Please also note that under § 512(f) of the United States Copyright Act, any person who knowingly makes a material misrepresentation that activities or materials are infringing a copyright may be subject to liability.

Counter-Notification

If you elect to send us a counter notice, to be effective it must be a written communication provided to our designated agent that includes substantially the following (please consult your attorney or review § 512(g)(3) of the United States Copyright Act to confirm the accuracy of these requirements):

(A) A physical or electronic signature of the user.

(B) Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled.

(C) A statement under penalty of perjury that the user has a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.

(D) The user’s name, address, and telephone number, and a statement that the user consents to the jurisdiction of Federal District Court for the judicial district in which the address is located, or if the user’s address is outside of the United States, for any judicial district in which we may be found, and that the user will accept service of process from the person who provided notification under subsection (c)(1)(C) or an agent of such person.

Such written notice should be sent to our designated agent as follows:

DMCA Complaints
HandsOn Connect Cloud Solutions
Chief Administrative Officer
12157 W Linebaugh Ave, #332
Tampa FL 33626

Email: dataprotection@handsonconnect.org

Please note that under Section 512(f) of the Copyright Act, any person who knowingly makes a material misrepresentation that material or activity was removed or disabled by mistake or misidentification may be subject to liability.

Please also be advised that it is our policy to terminate users’ access to and use of this Site or App in appropriate circumstances, where such users are repeat copyright infringers.