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Last Updated: [3/13/24]

This Privacy Policy (“Privacy Policy” and “Policy”) applies to the collection and use of Personal Information by Upwardly Global (“Company,” or “we,” or “us,” or “our”). It describes the Company’s practices regarding the collection, use, and disclosure of Personal Information when you visit our websites, use our mobile applications, use our Learning Management System (“Sites”), and when you engage with us offline. By using the Sites or engaging with us offline, you agree to the collection, use, and disclosure of Personal Information described in this Policy. It also describes the rights residents of the European Union, United Kingdom and California may have regarding their Personal Information. For the purposes of European data protection laws, Company is the controller of your Personal Information.

This Policy does not apply to information we collect about employees, people who apply for employment at the Company, and independent contractors. 

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  In the United States, it does not include de-identified or aggregate information, or public information lawfully available from governmental records. 

Personal Information We Collect and Have Collected– Sources and Categories

We may have collected your Personal Information when you visited our Sites, requested information about our products or services, provided us with your information at a conference or other event, clicked through links on our Sites to watch or listen to archived events or presentations, or voluntarily provided information to us through our web portal, email or phone number.  We will continue to collect Personal Information from the same sources.

The categories of Personal Information we may have collected from these sources include the following:  

  • Personal identifiers:  Name, address, email address, telephone numbers, IP address or other unique identifiers, account name, and other similar information.
  • Financial and insurance information: Bank account information, W9, Employer Identification Number (EIN), insurance information, and payment information.  
  • Protected class information: Age, military or veteran status.
  • Commercial information: Records of products purchased or considered, consuming histories or tendencies.
  • Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements.
  • Educational information: Educational history, degrees, and credentials. 
  • Professional information:  Name and location of current or past employers, professional qualifications, information on your resume or CV, position(s) you hold.
  • Geolocation information.
  • Audio and visual information: Recordings from video of telephone conference calls.
  • Inferences drawn from any of the Personal Information identified above.
  • Credit card information

Purposes for Collection of Personal Information

We have set out below a description of the ways we use your Personal Information (referred to as “processing purposes” below), and for individuals located in the EEA or the UK, we explain which of the legal bases we rely on to do so.  

Categories of Personal Information 

Processing Purposes 

Legal Basis (where you are located in the EEA or the UK) 

Personal identifiers; financial and insurance information; protected class information; commercial information; educational information; professional information; credit card information 

To provide our services to you: (i) to provide information you request and information on our products and services; (ii) to respond to your inquiries; and (iii) to provide you with news about the Company and for marketing purposes. 

To enter into / perform a contract with you (i.e., our Terms of Service) (Article 6(1)(b), GDPR). To pursue our legitimate interests in providing the requested information and/or information about our processing of your Personal Information in an effective and efficient manner (Article 6(1)(f), GDPR). 

Personal identifiers; financial and insurance information; credit card information 

To administer your donation: (i) to confirm that your donation has been received and provide you with a receipt (by sending a confirmation and thank you email); and (ii) to set up direct debits or process one-off donations. 

 

To pursue our legitimate interests in processing your donation and properly administering our relationship with you (Article 6(1)(f), GDPR) 

Personal identifiers; internet or other electronic activity information; geolocation information; audio and visual information 

Monitoring: (i) to understand your use of our Sites; (ii) to monitor or improve our Sites; and (iii) for internal business analysis. 

To pursue our legitimate interests to ensure our Sites are safe and secure and to ensure they are used in accordance with our Terms of Services (Art. 6(1)(f) GDPR). 

Personal identifiers; financial and insurance information; protected class information; commercial information; educational information; professional information; credit card information 

Legal Claims: to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.  

 

To comply with a legal obligation, e.g. to respond to an official request (Art. 6(1)(c) GDPR). 

If you are located in the European Economic Area (“EEA”) and the United Kingdom (“UK”): you have a right to object to the processing of your Personal Information where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil such requests in all instances. Where we need to collect the abovementioned categories of Personal Information by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and you do not provide this Personal Information when requested, we may not be able to comply with our legal obligations, provide you with the services or perform the contract we have or are trying to enter into with you. In such case, we may have to terminate our relationship with you. 

Disclosure of Personal Information

The following describes the categories of third parties with which we share personal information: 

The federal, state, and local government, other charitable organizations, private funders, educational institutions, service providers that provide services (including talent acquisition companies, providers that assist us in operating, analyzing, and displaying content on our website, providers of analytics information, providers that advertise or market our services, providers that host our Sites, providers of webcast and teleconference services, legal and accounting services, providers of data security services and cloud-based data storage, webcast and teleconference services, Social media platforms and providers of subscribers to our newsletter, and providers that assist with other IT-related functions), Bank, IRS, Sage (general ledger), and third-party Form 1099 preparers.

Additional Information About How We May Share Personal Information

We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities.  We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities.  And we may transfer your Personal Information to a third party in the event of a reorganization of our entity or other restructuring.  

We may share your personal information for the purposes described in this privacy policy with our affiliates, partners, consultants, vendors and service providers, subject to applicable confidentiality and data protection obligations. We will never rent, trade or sell your e-mail address or other personal information for commercial purposes. However, where we have received your consent if required by applicable law, we may agree with other reputable, charitable organizations to exchange a donor’s contact information in order to write via postal mail or e-mail to some of the other’s supporters in order to reduce costs and expand our audience. Donors have the right to opt-out of having their personal information shared by emailing Upwardly Global at optout@upwardlyglobal.org. 

Like most websites, our Sites use small data files stored on your computer or mobile device called cookies.  Cookies consist of two different types: session and persistent.  Session cookies enable us to recognize your actions during the browsing session.  Persistent cookies remain stored on your device after you close your browser until they expire or when you delete them. 

Cookies and Other Tracking Technologies

Cookies and web beacons, typically a one-pixel image, used to pass information from your computer or mobile device to our Sites, enable us to make improvements to our website and provide you with great customer service, product assortments and special promotions by: 

  • keeping track of what you have in your shopping cart;
  • remembering you when you return to visit the Sites;
  • identifying the pages you click on during your visit to the Sites;
  • the name of the website you visited immediately before clicking onto our Sites; and
  • helping track whether our communications are reaching you, measuring their effectiveness and allowing us to better design future communications.

We use this information to improve our site design, product assortments, customer service, and special promotions.  Certain cookies are strictly necessary to the access and operation of the website and other cookies used are non-essential to the access and operation of the website. 

We may contract with third parties who may use cookies and web beacons to collect information on our behalf or provide services such as data management, or website troubleshooting and analytics. These third parties are prohibited by our contract with them from sharing that information with anyone other than us or our other vendors who provide similar services. 

We use also Google Analytics to evaluate the use of our Sites.  Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website.  To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.

Security and Online Donations 

For your online security, we use a Payment Card Industry Data Security Standard (PCI DSS) compliant Level 1 Service Provider to process online donations pursuant to the highest industry standards and guidelines for PCI compliance.  No online credit or debit card information is received or processed directly by Upwardly Global. 

Opt-Out of Receiving Communications from Upwardly Global 

Our marketing platform provides users the opportunity to opt out of receiving communications from us through an Email Subscriptions / Preferences form linked at the bottom of the email you receive from Upwardly Global. You may choose to receive only specific communications or none at all. 

Your Privacy Rights 

In accordance with applicable law, you may have certain privacy rights depending on the jurisdiction in which you reside. However, please note that the below rights are not absolute and may be subject to limitations. 

EEA/UK Privacy Rights 

Individuals located in the EEA/UK may, subject to applicable limitations: (i) request access to, rectification or erasure of their Personal Information; (ii) request that the processing of their Personal Information be restricted; (iii) object to the processing of their Personal Information; and (iv) request a copy of their Personal Information to be provided to them or a third party in a digital format. Individuals located in the EEA/UK also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.  

International Data Transfers 

Our services are hosted in the US. Therefore, when you disclose Personal Information to us, this Personal Information will be transferred to the US.  If you are located in the EEA/UK, Company may, for the purposes listed above, transfer your Personal Information to other recipients as referred to above, that are also located in countries outside the EEA/UK including to the U.S., and which are not currently considered by the European Commission and/or UK Government to provide an adequate level of data protection. In these circumstances, Company will take steps to ensure that the Personal Information is protected including by entering into Standard Contractual Clauses or similar. You can request further information on the data transfer solutions relied upon, by using the contact details below.  

Retention of Personal Information 

We retain Personal Information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, the amount, nature and sensitivity of the Personal Information are considered, together with the necessity and purposes for the processing (including, whether such purposes can be achieved through other means) and the potential risk of harm from unauthorized use or disclosure of the Personal Information.  

Personal Information of Children 

We do not knowingly collect personal information from children or knowingly allow such persons to provide us with their personal information. Upon request, the parent or guardian of a child under 13 may review and request the deletion of the child’s personally identifiable information, as well as refuse to permit the further collection or use of such information.  If we discover that a user is under the age of 13, we will delete their personally identifiable information immediately. 

Third Party Websites 

Our Sites may contain links to third-party websites and applications, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Your use of such third-party websites and applications are governed by such third-party terms and privacy policies. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our Sites.

How We Keep Your Personal Information Secure 

We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer, or otherwise process.  Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of your Personal Information.  However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.      

Changes to This Policy 

We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been revised and by updating the effective date of the Policy.  

Contact Us 

If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at info@upwardlyglobal.org.