Last updated: April 20, 2022
It is important that you read this Policy, together with any other privacy or fair processing policy we may provide on specific occasions when we are collecting or processing your personal information so that you are fully aware of how and why we are using your personal information.
This Policy describes the types of personal information we may collect from you or that you may provide when you visit the websites mypromisetool.org and collegepromise.org (our “Website“), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Personal Information We Collect About You
“Personal information” is information from which you or other individuals can be identified. We collect several types of personal information from and about users of our Website, including information about:
- How to contact you, such as your name, postal address, e-mail address, and telephone number.
- Your workplace, such as position title, organizational affiliations, and similar information.
- Your internet connection, the equipment you use to access our Website, and usage details (see “Automatic Data Collection Technologies” section, below, for more information).
How We Collect Your Personal Information
We collect your personal information directly from you when you provide it to us. This will include personal information you provide:
- When filling in forms on our Website. This includes when you sign up for more information or for our newsletters, for events, to interact with various tools or to be part of specific communities; and request material, further information, or services.
- When you report a problem with our Website or contact us for any other purpose.
- When you respond to surveys that we might ask you to complete for research purposes through our Website.
- When you input queries using the “search” function on the Website.
- When you provide information to be published or displayed on public areas of the Website, or transmitted to other users of the Website or third parties.
We also collect your personal information through our use of automatic data collection technologies – see further in the “Automatic Data Collection Technologies” section below.
We may also collect or receive personal information about you from various third parties and public sources, including but not limited to:
- Technical Data from analytics providers, such as Google, and search information providers.
- Contact, financial and transaction data from providers of payment and delivery services.
- Identity and contact data from publicly available sources.
Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information from and about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
“Do Not Track” – Certain laws, including that of California, require that we inform you on our response to Do Not Track signals. As there is not an industry or legal standard for recognizing or honoring these signals at this time, we don’t respond to them.
The information we collect automatically is statistical data we may use to improve our Website and to deliver better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about preferences, allowing us to customize our Website according to individual interests.
- Speed up searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the “Choices About How We Use and Disclose Your Personal Information” section below.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit RPA, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
How We Use Your Personal Information
We may use your Personal Information:
- To present our Website and its contents to you (to achieve our legitimate interest in making this content available to you in an effective way).
- To provide you with information, products, or services that you request from us (with your consent).
- To carry out any other of our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (to perform our contract with you).
- To notify you about changes to our Website or any products or services we offer or provide through it (to achieve our legitimate interest in ensuring we provide our services to you effectively).
- To allow you to participate in interactive features on our Website (to achieve our legitimate interest in ensuring we provide our services to you effectively).
- To contact you about events, convenings, and information that may be of interest to you (with your consent).
- In the manner set out in the “Disclosure of Your Personal Information” section below.
If you do not provide RPA with the personal information required to perform our contract with you or comply with our legal or statutory obligations (highlighted as such in the list above), we may not be able to provide those relevant services to you.
If you consent to RPA’s use of your personal information and this consent forms the legal basis of our processing of that personal information, you are entitled to withdraw it at any time – see the “Your Rights With Respect To Your Personal Information” section below for more detail.
Disclosure of Your Personal Information
We may disclose personal information that we collect or that you provide as described in this Policy:
- To our subsidiaries and affiliates (the “RPA Group”) to provide you with requested services.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RPA’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of RPA, our customers, or others.
Choices About How We Use and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:
- Offers from RPA. If you do not wish to have your email address/contact information used by RPA to notify you of upcoming events or for our newsletter or other services, you can opt out by checking the relevant box located on the form on which we collect your data or by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to RPA as a result of a service engagement or other transactions.
We will only retain your personal information for as long as reasonably necessary to fulfill the purposes for which we use it, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, all information you provide to us is stored on our secure servers behind firewalls. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Policy
We may revise and update this Policy from time to time at our sole discretion. All changes are effective immediately when we post them and apply to all access to and use of the Website and handling of your personal information thereafter. It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page.
To ask questions or comment about this Policy and our privacy practices, contact us at:
Address: Rockefeller Philanthropy Advisors 6 West 48th St. New York, NY 10036