Privacy Policy

Privacy Policy

Master Privacy Policy and Express Consent

  1. Preamble

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, processing, transferring and disclosure of “personal information” by Open Thread Media, LLC and this website (“Crasstalk” or “Website” or “OTM” or “Open Thread Media”), a Delaware limited liability company, and also contains an Express Consent that applies to those who use our Websites and Services (as defined below).

Unless otherwise noted on a particular website or service hosted by Open Thread Media, LLC, this Privacy Policy applies to your use of all websites that Open Thread Media operates. These include,,, together with all other subdomains thereof (the “Crasstalk Website”), (collectively, the “Websites”). This Privacy Policy also applies to all products, information, and services provided through the Websites, including without limitation the website, open thread posts, author accounts, and comments.

In addition, supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to particular third party Services, such as the Intense Debate commenting system and accounts that can be used to login to Intense Debate from All such Supplemental Privacy Policy Terms will be accessible for you to read either within, or through your use of, that particular Service.

This Privacy Policy also explains our commitment to you with respect to our use, processing, transfer and disclosure of non personal browsing and site usage data that Open Thread Media collects as the provider of the Services. “Non personal browsing and site usage data” refers to information that OTM collects indirectly and automatically about your activities while visiting the Websites and using the Services through tools such as Google Analytics. The type of information that we collect focuses on general information such as general location such as country or city where you are located (not intentionally fine-grained location information), pages visited, heat-map of visitors’ activity on the site, information about the browser you are using, etc. In addition, whenever you use a Login Service to log into a Website or use the Services, our servers (which, again, are hosted by a third party service provider) keep a plain text log of the websites you visit and when you visit them. OTM does not deliberately track people over the Internet. See section 11, below for more information about this.

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address or information from which a person could deduce your identity.

By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.

  1. Our Principles

OTM is committed to handling responsibly the personal information and data we collect and process about you through our Services, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy consistent with the following principles (the “Principles”):

  • Privacy policies including provisions regarding data collection, processing and use, should be human readable, comprehensive, and easy to locate;
  • Only the minimum amount of personal information reasonably necessary to provide you with services should be processed, collected and maintained, and only for so long as reasonably needed or required, consistent with the principles of proportionality; and
  • Personal information you provide through our Services, or that we gather as a result of your use of our Services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required.
  1. Personal Information OTM Collects

We may collect and process personal information through our Services, including without limitation:

  • when you provide us with your personal information such as by sending an email to us or signing up to receive email notifications;
  • when you subscribe to one of our email discussion lists;
  • when you donate money to us or purchase merchandise;
  • when you create a local WordPress account;
  • when you create an Intense Debate commenting account;
  • if you email us;
  • when you provide personal information in connection with your participation in any of the open thread forums we make available through our Services.

Specifically, the following personal information at a minimum will be collected, processed and transferred as set forth below when you use our Website:

  • User name (as you provide it);
  • Email address;
  • Brief bio in Intense Debate (including links and references);
  • URLs and links to social media;
  • A personal photo for your profile through the Gravatar service (if you voluntarily supply a photo); and
  • Any other information that you elect to provide or that OTM may request.

Some of this personal information (along with your new user ID) will be used to create your WordPress and/or Intense debate member profile if your application is approved. Some of that information will be public (user name and photo (if the feature is enabled and you have voluntarily supplied it), and if entered your brief biography, URLs and social media, and similar)).

  1. What OTM Does with Personal Information

Emails and Newsletters . We use the personal information you provide to us when you send us emails or sign up to receive updates from OTM in order to respond to your request – for example, to reply to your email or to send you communications about OTM news and campaigns.

When you subscribe to updates from us, your email address is sent to and stored in an email account hosted on servers that can only be accessed by OTM staff and are operated by Google.

Events: If you sign up for an event hosted or supported by OTM, we may share your personal information with other event attendees solely for the purpose of organizing and running the event.

Donations . When you donate money, goods or services to us, purchase merchandise via our support page, your personal information will be provided to us by PayPal including your name and email address associated with your PayPal account.

You may donate money to OTM directly or through the on-line payment site PayPal. When you use PayPal to donate to OTM, your personal information is sent to, processed by and stored by those websites in accordance with their respective privacy policies and terms of use. You should read and understand the privacy policy and terms of use of any website you use to donate to OTM.

  1. Disclosures of Personal Information

In general, it is not OTM’s practice to disclose personal information to third parties other than as made available on the Services. Except as otherwise set forth herein or for providing you with attribution using your WordPress or Intense Debate OTM Login Service user name, we may share your personal information in the following instances:

  1. First, OTM may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services, to organize and run an event you signed up to attend, to evaluate your application for funding and/or participation in a program run by OTM, or to otherwise run any OTM program or activity in which you have chosen to participate.
  2. Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms and this Privacy Policy; (c) enforce our Charter [link] including the Code of Conduct and policies contained and incorporated therein, (d) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (e) address legitimate interests pursued by OTM 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 data, in particular where the data subject is a child) and ensure our compliance with applicable laws.


  1. Security of Personal Information Collected via the Services

OTM has implemented reasonable physical, technical, and organizational security measures for personal information that OTM processes, transfers, stores and controls against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

The third party login services such as and Intense Debate have their own security measures and notification procedures in place.

  1. Information from Cookies and Similar Technologies

We and our service providers (for example, Google Analytics as described in section 1 above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device.  Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities.  The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

  1. Non Personal Browsing and Site Usage Information We Process and Collect

When you use the Services, our servers (which may be hosted by a third party service provider) may process and collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and using our Services, and information about the country you are located in and the browser you are using. In addition, we use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about the use of the Websites and Services, and to report trends, without identifying individual visitors (this is all “non personal browsing and site usage information” for purposes of this Privacy Policy and as described in section 1, above). The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at Whenever you use your Intense Debate or WordPress local website account, our servers (which, again, are hosted by a third party service provider) keep a log of the websites you visit and when you visit them. We may share the non personal browsing information we collect with our third party service providers in connection with the services they provide.

  1. No Linking

We do not intentionally link browsing information or information from our OTM Login Services server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. OTM may use a third party analytics provider (for example, Google Analytics as discussed in section 1 above) to help us collect and analyze non personal browsing and site usage information through operation of our Services for those same purposes.

In connection with your use of the Services, you may tag content, create lists of favorite content, and do other things to personalize your experience. You should not, however, tag other persons or post photographs or other images or likenesses without that other person’s express consent. This information will be retained by OTM in connection with the relevant OTM Login Service.

  1. No Selling or Sharing

Except in the unique situations identified in this Privacy Policy, OTM  does not sell or otherwise voluntarily provide the non personal browsing information we collect and process about you or your website usage to third parties.

  1. No Access; More about OTM Website Login Services

As a provider of OTM Login Services, OTM could access your local WordPress web-based account tied to such services, and could log in on behalf of any of Registered Users to any of the accounts they have accessed using the OTM Login Services. OTM will never use this technical login ability for any purpose except as required by law.

  1. Data Retention

OTM generally discards non personal browsing information from our Services and website once we have used the information for the limited purposes noted above under “No Linking” and described elsewhere in this Privacy Policy. Nevertheless, we may, but are not obligated to, retain certain data in connection with routine information technology backups and for archival purposes.

  1. Notice

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles.

  1. Reorganization or Spin-Offs

OTM may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, OTM will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles and with all applicable laws.

  1. Children

The Services are not directed at children under the age of 13. Consistent with the U.S. federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms specifically prohibit anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to OTM through the Services represents that they are 13 years of age or older.

  1. Third-Party Sites

The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

  1. Special Note to International Users

If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. The Services are hosted in the United States and the United Kingdom. Please note that your personal information may be located on servers in the United States and/or the United Kingdom. By providing your personal information and by checking all required boxes when you create an account or otherwise access and use our Services or Websites, you expressly consent to the use of your personal information for the uses identified above in accordance with the Privacy Policy.

Data transferred from the European Union to the United States or outside the European Union will be made on the grounds of a certification to the E.U./U.S. Privacy Shield regime and/or a data transfer agreement based on the Standard Contractual Clauses approved of by the European Commission respectively, consistent with applicable data privacy requirements.

  1. Accuracy of Personal Information Collected

OTM intends to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to carry out the purposes described in section 3 above, or as required by law. If changes need to be made to your personal information, please notify us (as identified below, see the “Questions” section) right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in personal information, we will promptly make changes as appropriate. You also have the option to update some of your personal information yourself via your OTM account or profile if you have one.

  1. Access to Personal Information

Along with all other rights granted to you under applicable laws, you may at any time request to be informed of personal information that OTM holds. If you wish to access such personal information, you should apply in writing to OTM (as identified below, see the “Questions” section). You are generally entitled to access personal information that OTM holds and to have inaccurate data corrected or removed to the extent OTM still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information.

  1. Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services, and will revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.

  1. Using this Privacy Policy for Your Own Purposes

The text (but not trademarks, including OTM’s name, branding, and look-feel of this site) of this Privacy Policy is dedicated to the public domain under the Creative Commons CC0 Public Domain Dedication. You are free to use and adapt this Privacy Policy and any applicable Supplemental Privacy Policy Terms for your own purposes but not in connection with the Services of Websites. These terms are provided AS-IS and without any warranty of any type whatsoever (see the text of the CC0 for more). Keep in mind that this Privacy Policy may not be suitable for your situation. OTM strongly encourages you to seek the advice of your own attorney before repurposing this Privacy Policy on your own site. OTM is not your attorney, and this is not legal advice.

  1. Questions?

If you have questions about this Privacy Policy, please contact us by email at [email protected].

Effective Date: April 12, 2018.