Effective Date: May 31, 2023
- INFORMATION WE COLLECT OR RECEIVE
- DISCLOSURE OF INFORMATION
- DATA SECURITY AND DATA RETENTION
- YOUR CHOICES: RIGHT TO WITHDRAW CONSENT; OPT-OUT; UNSUBSCRIBE
- SPECIFIC LEGAL CONSIDERATIONS
- ADDITIONAL INFORMATION
INFORMATION WE COLLECT OR RECEIVE
Information We Collect Directly from Users
We may collect information provided directly by users of the EC Services (“User-Provided Data”), including the following:
From Volunteers and Potential Volunteers:
- Name, other personal data “Identifiers” (which may include address, email address, and telephone number), and social media (such as LinkedIn) profile information
- Race/ethnicity and preferred pronoun
- Professional experience and skills
- Other information that the volunteer/potential volunteer directly provides to us, including information relevant to determining suitable volunteer roles and responsibilities
From Funding and Program Recipients/Applicants:
- Name, other personal data “Identifiers” (which may include address, email address, and telephone number), and social media (such as LinkedIn) profile(s)
- Social security number or other federal identification number
- Driver’s license number or other government-issued identifier (e.g., passport number)
- Financial account information
- Demographic information, such as:
- Date of birth
- Racial/Ethnic category(ies)
- Gender-related information
- Sexual orientation
- Mental and/or physical health condition(s) and/or diagnosis(es) age, gender, education, income, and household status (e.g., number of children))
- Other information that the recipient/applicant directly provides to us
- Name and other personal data “Identifiers” (which may include address, email address, and telephone number)
- Other information that the donor directly provides to us (but not financial account information – see below)
- Name and other personal data “Identifiers” (which may include email address and telephone number)
- Other information that the user directly provides to us
We may use User-Provided Data: (i) to place volunteers in roles intended to utilize their skills, experience, and interests to support the Colorado small businesses that we work with; (ii) to evaluate and select Colorado small businesses for loans from the Gap Fund and/or to originate, underwrite, and/or service such loans; (iii) to provide information (including marketing and promotional information) about our programs and services, which use may include uploading such data (including email addresses) to third-party service providers, such as Facebook and Google, to have customized ads served to such users and/or to people similar to such users; (iv) for research, reporting, and analytics; and (v) for other operational purposes, including (a) to otherwise provide, maintain, analyze, develop and improve the EC Services and (b) for validation/authentication and other security purposes in connection with the EC Services.
We use a third-party plugin (currently, GiveWP) in connection with the processing of donations through the EC Site. If you provide a financial account number (e.g., credit card number or debit card number) to make a donation to us through the EC Site, please be aware that: (i) you are providing such financial account number to such third-party plugin (not to us); (ii) we do not access, store, or otherwise process such financial account number; and (iii) the processing of such financial account number and any and all other data required or otherwise collected by such third-party plugin (e.g., name, email address, phone number, postal address, commercial information, etc.) is subject to the applicable terms, conditions, and policies of such third-party plugin (each of which may be modified from time to time by such third-party plugin). We may receive from, and provide to, the third-party plugin provider a randomly-generated payment “token” in connection with your donations.
Information We Collect via the EC Activity Sites; Information We Receive from Third Parties
When you view and interact with the EC Site, and/or with third-party websites, apps, and other digital properties on which we may advertise (collectively, “Advertising Sites”; together with the EC Site, “EC Activity Sites”), we may collect (i) information about the interactions that you have with the EC Site and/or with our advertising on the Advertising Sites, (ii) information about the EC Activity Sites, and (iii) information that identifies your browser(s) and device(s) (collectively, “Activity Data”). Activity Data includes “Online Technical and Activity Information”, such as:
These technical identifiers can be used to identify an individual’s browser, mobile advertising environment, and/or device, and typically include:
- Cookie IDs
- Mobile advertising IDs (such as Apple IDFAs and Google Advertising IDs)
Additional Technical Information
- Internet protocol address (“IP address”) and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a device
- Type of Internet browser, browser language, and operating system
- Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available)
- A “cookie” is a small alphanumeric text file that is stored in a browser by a website or by a third-party ad server or other third party that allows that website or third party to recognize that browser and to remember Online Technical and Activity Information, User-Provided Data, and other information. Cookies are typically divided into two types: “session” cookies (which are deleted when the user ends their session by closing their browser) and “persistent” cookies (which, by contrast, are stored on the user’s device after they end their session).
- An “advertising ID” is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognize a particular device in an application environment and that may be associated with Online Technical and Activity Information, User-Provided Data, and other information.
- A “pixel” is a line of code that is used by a website or other digital property to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID.
We may use Online Technical and Activity Information, either by itself or together with User-Provided Data, other Activity Data, and/or other data we have collected or received, in order (i) to make our advertising more useful and relevant and (ii) to understand and improve the effectiveness of that advertising. We call this type of advertising “Tailored Advertising”, and we typically use third-party vendors in connection with such advertising. Tailored Advertising is sometimes also called “online behavioral advertising”, “interest-based advertising”, “cross-context behavioral advertising”, or “targeted advertising”. Our advertising may be delivered across computers, smartphones, and other devices, as well as offline channels, and our third-party vendors may connect information (including information relating to browsers, environments, and/or devices) that they reasonably believe to be associated with the same user in order to help us provide more useful and relevant advertising regardless of browser, environment, device, or channel.
We, directly and/or through our third-party vendors (including Google Analytics), may also use Online Technical and Activity Information to understand and improve the effectiveness, performance, content, and security of the EC Services, and for administrative and other security purposes. To learn more about Google’s use of information collected on the EC Site through Google Analytics, please visit www.google.com/policies/privacy/partners/.
We may receive financial-related information (such as credit score of a sole proprietor or the sole member of a single-member LLC) from financial institutions and/or credit-reporting agencies (“Financial-Related Data”). We use Financial-Related Data in connection with our lending programs and services, including to decide whether to originate, underwrite, and/or service a particular loan.
DISCLOSURE OF INFORMATION
In furtherance of their missions, Energize Colorado and Gap Fund may commingle and share data and information among themselves and with any subsidiaries that Energize Colorado and/or Gap Fund may form in the future. In addition to the sharing of data and information between Energize Colorado and Gap Fund, we may share data and information with third parties as follows:
Types of Data
We may provide User-Provided Data to: (i) third-party service providers that agree to use it only to provide services to us; (ii) the State of Colorado and its applicable agencies, political subdivisions, and entities in connection with our programs and services, including the services we perform for them (collectively, “Colorado Entities”); (iii) financial and/or lending institutions and/or organizations (including those that may originate, underwrite, and/or service loans and/or provide other financial services) and/or credit-reporting agencies, in each case in connection with our programs and services; and (iv) other resources, entities, and advisors with whom we partner in connection with the EC Services.
We may allow third-party vendors that provide us with advertising (including Tailored Advertising) services, marketing services, analytics services, and/or security services to collect Activity Data on the EC Site.
We may provide Financial-Related Data to: (i) third-party service providers that agree to use it only to provide services to us; (ii) Colorado Entities; (iii) financial and/or lending institutions and/or organizations (including those that may originate, underwrite, and/or service loans and/or provide other financial services) in connection with our programs and services; and (iv) other resources, entities, and advisors with whom we partner in connection with our programs and services.
Transfer of Data in the Event of Acquisition
In the event that another company acquires all or a majority of the assets of our business through a consolidation, merger, stock purchase, asset purchase, corporate reorganization, or other transaction, we reserve the right to transfer all information that is in our possession or under our control to the acquiring party.
Transfers Legally Required; Transfers in connection with Prohibited Activities or for Security
If and to the extent we reasonably believe we are obligated by law, rule, regulation, or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor, advisor, or other service provider) in order to investigate, prevent, and/or take action regarding suspected or actual prohibited activities and/or in order to review, evaluate, and/or address the integrity and security of the EC Services.
DATA SECURITY AND DATA RETENTION
Data security is important to us, and we strive to implement reasonable and appropriate technical and organizational measures to protect against unauthorized access to, unauthorized or unlawful use of, and unauthorized disclosure of data, with respect to both data at rest and data in transit. Please keep in mind, however, that despite our efforts to keep data secure, no storage or transmission of information can be guaranteed to be completely secure.
YOUR CHOICES: RIGHT TO WITHDRAW CONSENT; OPT-OUT; UNSUBSCRIBE
In browser environments, you may opt-out of Tailored Advertising via our third-party vendors by utilizing any of the following methods:
- Adjusting your browser settings to refuse or remove cookies, which would result in the cessation of Tailored Advertising via cookies from third-party vendors. However, by doing so, you may not be able to use certain features on certain websites or take full advantage of all website offerings. You may refuse or remove cookies by following the directions provided in your browser settings. Additional information about cookies is available at www.aboutads.info/consumers#cookies.
- Adjusting the cookie settings at the level of the website owner where you granted consent to that cookie usage; cookie settings options may vary by website owner.
- “Opting out” of Tailored Advertising via the targeting cookies of third-party vendors, at www.aboutads.info/choices.
Please note the following about opting out of targeting cookies:
- “Opting out” generally results in a unique targeting cookie being replaced on the applicable browser with a non-unique “opt-out” cookie.
- An opt-out election applies only to the browser where the choice to opt out was effected. For example, if you opt out in your Chrome browser on a particular device, that choice will not apply to any other browser you have on that device. To opt out in another browser, you would need to repeat the opt-out process.
- In order for the opt-out process to work, your browser must be set to accept third-party cookies.
- If, after you have opted out, you buy a new device, upgrade or change web browsers or delete an opt-out cookie(s), you would need to perform the opt-out process(es) again.
In mobile application environments, you may also elect not to receive or to receive (depending on the mobile device operating system) “interest-based advertising”/“online behavioral advertising”/Tailored Advertising via the privacy settings on your mobile device and as otherwise made available by the applicable mobile device operating system.
Additional information regarding user choice in application environments is available at:
Email, Text, and Direct Mail Marketing
If you no longer want us to send you marketing and/or promotional information by email, text, and/or postal mail: (i) you may unsubscribe from receiving our marketing and promotional emails by following the unsubscribe link in such marketing and promotional emails; (ii) you may unsubscribe from receiving our text message marketing and promotions by replying STOP (or CANCEL, UNSUBSCRIBE, END, or QUIT, as applicable) to any such text message; and (iii) you may unsubscribe from receiving our postal mail (“direct mail”) marketing and promotions by emailing us at [email protected].
SPECIFIC LEGAL CONSIDERATIONS
None of the EC Services is intended for or directed at children (as defined by applicable law). We do not knowingly collect information from children on the EC Site or through any of our programs or services. If you believe a child has provided us with personal data, or that we may have otherwise collected or received personal data from a child, and you would like to have such information removed, please contact us by email to [email protected].
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of “personal information” that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of third-party companies, if any, to which we have provided personal information for our own marketing purposes, please contact us by email to [email protected] Please allow 30 days for a response.
Do Not Track
We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
None of the EC Services is intended for or directed at individuals in the European Economic Area, the United Kingdom, and/or Switzerland (each, a “European Jurisdiction”). If you are a European Jurisdiction data subject, you have the following data protection rights under applicable law:
- Right of Access. You have the right to access your personal data.
- Right to Erase. You have the right to have us erase your personal data.
- Right of Rectification. You have the right to have your personal data rectified/updated if that information is inaccurate or incomplete.
- Right to Object. You have the right to object to our processing of your personal data carried out for our legitimate reasons and/or for direct marketing, including profiling that is related to such direct marketing.
- Right of Restriction. You have the right to request that we restrict the processing of your personal data (i.e., we would need to secure and retain the personal data for your benefit but not otherwise use it).
- Right to Data Portability. You have the right to be provided with a copy of your personal data in a structured, machine-readable and commonly used format (or have this transferred to a third party).
- Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal data.
If you are a European Jurisdiction data subject, believe that we have unintentionally processed your personal data, and wish to exercise one of the above-mentioned rights, please send us your request via email to [email protected].If you are a European Jurisdiction data subject, you also have the right to complain to a data protection authority about our collection and use of your personal data. (If you are a resident of the European Economic Area, you can find your local supervisory authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.) We would, however, appreciate the opportunity to address your concerns before you engage a data protection authority, and would welcome you directing an inquiry first to us at [email protected].
Third-Party Websites and Other Digital Properties