Privacy Policy

Community Partners International (“CPI”) respects your privacy concerns and aims to inform and empower you concerning your personal information.

Throughout these Terms, you will see the terms “Community Partners International” “CPI,” “we,” “our,” and “us.” These terms refer to Community Partners International, a California public charity with tax-exempt status pursuant to Internal Revenue Service Code Section 501(c)(3). You will also see the terms “I,” “you,” “your,” and “yours.” These terms refer to visitors to and users of this Site. By “personal information”, we mean any information relating to an identified or identifiable individual.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

This Privacy Policy describes the types of personal information we obtain, how we may use that information, with whom we may share it, how we protect it, and the choices you can make about our use of the information. This Privacy Policy applies to the personal information we obtain through your use of our website, cpintl.org, and other websites that link to this Privacy Policy (the “Site”); your offline interactions with us, including when you connect with us via telephone, at our events, and through our surveys; and through our third-party sources, including advertising and social media networks (collectively, the “Channels”). Please see our Donor Privacy Policy for more information about our privacy practices concerning donor information.

Personal Information Collected

We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Your real name, alias, work postal address, unique personal identifier, online identifier, Internet Protocol address, work email address, or other similar identifiers.
• Your work address, work phone number, work email address, education, employment, and/or employment history.
• Records of products or services considered or inquired about.
• Information regarding your interaction with an Internet Web site, application, or advertisement.
• Publicly available information regarding your procession, current employer, and past employers.
• Inferences drawn from any of the information identified above to create a profile about you reflecting your interest in certain products or services.
• Other personal information contained in the content you choose to submit to us.

This personal information is required to provide products and/or services to you and/or to connect you with products or services in which you have indicated or demonstrated an interest. If you do not provide the personal information we ask for, it may delay or prevent us and/or our customers from providing such products and/or services to you.

If you choose to make a gift to CPI, whether by telephone, postal mail, or this Site, we may obtain additional information in connection with your donation, including your payment information (such as credit or debit card or bank account number). Concerning planned gifts, we also may collect information such as your Social Security number (where required by law) and estate documentation. If you apply for a job opportunity with CPI, we also may collect your resume (which may include information such as your work experience and education history).

In addition, when you visit the Site, we may obtain certain information by automated means, such as through cookies and web beacons. The information collected in this manner may include IP address, user device ID, user location, browser language, screen resolution, operating system, service provider and other system settings or information, and your actions while browsing a website. Your browser may tell you how to restrict or disable certain types of cookies. For more information about the cookies used on our Site, please visit our Cookie Policy. Please note, however, that without cookies, you may not be able to use all of the features of our website.

We may use third-party web analytics services on our Site, such as Google Analytics. These service providers help us analyze how users use the Site and which links they clicked on to arrive at the Site. The information collected by the cookies and web beacons (including your IP address) will be disclosed to these service providers, who use the information to evaluate your use of the Site. To learn about Google Analytics and how to opt out, please visit http://tools.google.com/dlpage/gaoptout and https://www.google.com/policies/privacy/partners/.

Please note that third-party service providers process online donations on this Site, and you should read the section below entitled “Links and Third Party Web Sites” and familiarize yourself with the privacy terms of all such non-CPI sites before using them.

How Your Personal Information is Collected

• From publicly accessible sources (e.g., social media);
• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
• From a third party with your consent (e.g., companies you do business with);
• From cookies and similar technologies on our website or that of our customer(s) and/or through direct email communications with you.

How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

We may use the personal information we obtain:

• to send you materials or information that you have requested,
• to send you materials, information, or other communications that may be of interest to you,
• to manage our fundraising activities and process donations,
• to respond to your inquiries,
• to communicate with you to administer your participation in surveys,
• to personalize communications and fundraising efforts that we believe will be of interest to you,
• to comply with applicable legal requirements, industry standards, and our own policies and terms,
• for our operational purposes, including data analysis, identifying usage trends, enhancing our websites and promotional campaigns, and
• as otherwise described in this Policy.

The above does not apply to special-category personal information, which we will only process with your explicit consent.

We also may use the information in other ways for which we provide specific notice at the time of collection. Additionally, we may use information obtained through automated means for various purposes, such as customizing our visitors’ visits to the Site and understanding how our visitors browse and use the Site. We also may use this information to help diagnose technical and service problems, administer the Site, identify visitors, and gather demographic information about our visitors.

Promotional Communications

We may use your personal information to send you or assist in sending you information and updates (by email, text message, telephone, or post).

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and will only share it with other organizations for marketing purposes with your consent or pursuant to legitimate interests.

You have the right to opt out of receiving promotional communications at any time. To update your preferences, ask us to remove your information from our mailing lists, or submit a request, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future or if there are changes in the law, regulation, or the structure of our business.

Interest-Based Advertising

On our Site, we may obtain information about your online activities to provide you with advertising about fundraising opportunities that may be tailored to your interests. This section of our Privacy Policy provides details and explains how to exercise certain choices.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users by considering demographic data, users’ inferred interests, and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information that ad services may collect includes data about your visits to websites that serve our advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Site and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/.

Disclosure of and Access to Your Information

Subject to applicable law, we may disclose your personal information:

• to affiliated entities (e.g., on whose behalf we may process donations),
• to third parties, including our vendors, attorneys, accountants, and advisors, who provide CPI with assistance or advice or are under contract to perform services for or on behalf of CPI (collectively, “Service Providers”),
• consortium groups and third parties acting on behalf of non-profit organizations that combine your personal information with information from other sources for analytical purposes,
• in connection with merger and acquisition activity, reorganization or other disposition of part or all of CPI,
• if we are required to do so by law, regulation, or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, or
• if you direct us to do so.

We also may share donation-related information, such as information about charitable gift annuities, with the Internal Revenue Service.

Your personal information will not be shared, leased, or sold to other organizations for fundraising purposes unless you have provided CPI with specific permission or as otherwise disclosed in this policy. CPI will not send donor mailings on behalf of other organizations.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and you.

Where Your Personal Information is Held

Information may be held at our offices and third-party agencies, service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

We will keep your personal information while we are providing products and/or services to you or for your benefit. After that, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints, or claims made by you or on your behalf;
• To show that we treated you fairly or
• To keep records required by law.

Transferring Your Personal Information Out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• With our offices outside the EEA,
• With your and our service providers located outside the EEA,
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection laws. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection laws and that all personal information will be secure.

If you would like further information, please contact us (see “How To Contact Us” below).

Your Rights Under the GDPR

Right to Access: The right to be provided with a copy of your personal information (the right of access).

Right to Rectification: The right to require us to correct any mistakes in your personal information.

Right to be Forgotten: The right to require us to delete your personal information—in certain situations.

Right to Restriction of Processing: The right to require us to restrict the processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.

Right to Data Portability: The right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.

Right to Object: The right to object

• at any time to your personal information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

• The categories of personal information we have collected about you
• The categories of sources from which the personal information is collected;
• Our business or commercial purpose for collecting or selling personal information;
• The categories of third parties with whom we share personal information, if any; and
• The specific pieces of personal information we have collected about you

Please note that we are not required to:

• Retain any personal information about you that was collected for a single, one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information or
• Provide the personal information to you more than twice in a 12-month period

Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.

Under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, you have the right to opt out of the sale [or disclosure] of your personal information. If you exercise your right to opt out of the sale or disclosure of your personal information, we will refrain from selling your personal information unless you subsequently provide express authorization for the sale of your personal information. To opt out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, and provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise, use your personal information internally in a lawful manner compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Links and Third-Party Websites

The Site contains hyperlinks or “links” to other sites, including access to our affiliated and non-affiliated sites’ content, products, and services. For example, online donations to CPI are facilitated by our non-affiliated service provider. When you follow links on our Site, you may be directed to a third-party website subject to a separate privacy policy and other terms and conditions. Sometimes, these other websites are made available via “framing technology” and may appear as part of our Site. Before submitting personal information, we urge you to familiarize yourself with the individual privacy policies and other terms for each linked or framed site. We are not responsible for the data collection, privacy, and information sharing policies and procedures or the content of such websites.

Your Options

To update your preferences, ask us to remove your information from our mailing lists, or submit a request, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.

Children’s Personal Information

The Site is designed for a general audience and is not directed to children under 13. The Site does not knowingly collect or solicit personal information from children under 13. If you believe a child under 13 may have provided us with personal information, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.

How We Protect Your Personal Information

We maintain administrative, technical, and physical safeguards to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Changes to This Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions or comments concerning this Privacy Policy, please email us at info@cpintl.org or write to us at Community Partners International, 580 California St Fl 16, Ste 1658, San Francisco, CA 94104-1068, USA.

Last Updated: September 17, 2024