Last Updated: [7/03/24]
This Privacy Policy (“Privacy Policy” and “Policy“) applies to the collection and use of Personal Information by Upwardly Global (“Upwardly Global,” or “we,” or “us,” or “our”). It describes Upwardly Global’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 (together, the “Services”). By using the Services, 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 the United States may have regarding their Personal Information. For the purposes of European data protection laws, Upwardly Global 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 Upwardly Global, and independent contractors.
For purposes of this Policy, “Personal Information” means information that can be reasonably linked with a particular consumer or household or as otherwise defined by applicable law. 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
Depending on your interactions with our Services, we collect your Personal Information when you use our Services, visit our Sites, request information about our products or services, provide us with your information at a conference or other event, click through links on our Sites to watch or listen to archived events or presentations, or voluntarily provide information to us through our web portal, email, or phone number. We may otherwise collect Personal Information through publically available sources, such as social media. 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.
- 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.
- Demographic Information: Racial and ethnic identity, sexuality and gender, and disability 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, field of education, degrees, degree evaluations, work authorizations status, 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: General location information, including zip code.
- Audio and visual information: Recordings from video of telephone conference calls.
- Inferences drawn from any of the Personal Information identified above.
- Payment Information: Credit card information.
- Social Media Information: Social media profile information, including LinkedIn profile.
Sensitive Information
We collect, use, or process Personal Information, which is classified as sensitive under certain US or foreign legislation, only when necessary to provide our Services. We obtain consent to collect sensitive information, or allow users to decline to input this information, where required by law.
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; (iii) to communicate with you; and (iv) to provide you with news about the Upwardly Global 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; protected class information; demographic information; commercial information; educational information; professional information; audio and visual information; social media information | To provide our services to employers and partners: (i) to provide employers with the products and services they purchase. | To enter/perform a contract with you (i.e., our Terms of Service) (Article 6(1)(b), 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; protected class information; demographic information commercial information; educational information | To conduct research and improve our organization: (i) to conduct research, such as questionnaires and surveys; and (ii) to analyze and enhance our marketing communication strategies. | To pursue our legitimate interests in data research (Article 6(4) 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). |
Personal identifiers; financial and insurance information; protected class information; demographic information; commercial information; educational information; professional information; credit card information; geolocation; inferences | Other Legal Means. We use your information consistent with this Privacy Policy for any legal purpose. | This may include compliance with a legal obligation, with your consent, or for our legitimate interests in accordance with the 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 fulfill 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 in the event of a reorganization, merger, purchase, transfer of ownership or assets, or other corporate reorganization.
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.. 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.
Cookies and Other Tracking Technologies
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 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 your purchases and donations;
- 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 use this information to improve our site design and functionalities, product assortments and services, customer service and support, and special promotions. Certain cookies are strictly necessary to the access and operation of the website and other cookies used are nonessential 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. You can opt out of Google Analytics tracking here.
Our Sites employ “pixel tracking”, a common process which may be used in connection with advertisements on other websites.
Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products and services with your interests and needs. For example, if you visit our Sites from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Sites.
We specifically incorporate “pixels” provided by Meta Platforms, Inc. on upwardlyglobal.org. This enables us to track user behavior after a user clicks on a Facebook ad and is redirected to our Services. By doing so, we can assess the effectiveness of Meta ads for statistical and market research purposes and sometimes retarget certain users. Please note that the data collected through this process remains anonymous to us, meaning we do not have access to personal information of individual users. However, Meta stores and processes this data. It is important to be aware that Meta may associate this information with any of your Meta accounts and utilize it for its own promotional activities. You can learn about Meta’s privacy practices by visiting the Meta Privacy Notice.
We have not sold your Personal Information for monetary value. However, our use of cookies and other website tracking technologies on our Sites may be considered a sale under applicable data protection laws.
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.
U.S. Privacy Rights
Certain U.S. states, including Delaware and Colorado, provide certain rights to their residents. Subject to applicable limitations, certain residents may: (i) request access to, correction, or deletion of their Personal Information; (ii) request a copy of their Personal Information to be provided to them or a third party in a digital format; (iii) opt out of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects; (iv) only have sensitive information processed with consent. Nevada law gives Nevada residents the right to opt-out of the sale of their Personal Information. Please note we do not “sell” data as defined by Nevada law.
International Privacy Rights
Individuals outside the United States, including those residing in Canada, China, and certain other jurisdictions may have certain data subject rights. These rights vary, and may be different from those listed within this Policy.
Exercising Privacy Rights
To exercise any of the above options, you may contact us at the information provided below.
Please include your email address, full name, and specific information about your request(s). If you would like to update or correct your email address, work address, or other Personal Information with us, please include specific details about the information you wish to have updated or corrected.
You must provide enough information that allows us to verify your identity. Only you or your authorized agent may make requests regarding your Personal Information. An authorized agent must have documentation that they are authorized to act on your behalf.
We will fulfill or reject your request within the amount of time required by law. The response we provide will also explain any reasons we cannot comply with a request, if applicable. If we deny your rights request, you have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at the information provided in this Notice.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have the right to not experience discrimination from us for exercising the rights listed in this section. However, limiting use of, or deleting, your Personal Information may restrict the purposes or uses that rely on that information, and we may be unable to provide you with certain services as a result.
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, Upwardly Global 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, Upwardly Global 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 fulfill 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 thirdparty 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.
Personal Information Storage
We use several criteria to determine how long we should keep categories of Personal Information. We will retain your Personal Information for the time period reasonably necessary to achieve the purposes outlined in this Privacy Policy to the extent permitted by applicable law.
Please understand that residual copies of the Personal Information can be stored in locations or formats that make complete erasure extremely difficult. The best way to ensure you control your information is to give us only the Personal Information that you are completely comfortable sharing with us.
Do Not Track Signals
CalOPPA requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time.
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
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