CODE TENDERLOIN
Privacy Policy
Last Updated: November 13, 2019
Independent Arts and Media (“IAM”) operating through the Advisory Board of Code Tenderloin (“Code Tenderloin”) is committed to protecting your privacy. We have prepared this policy (the “Privacy Policy”) to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.codetenderloin.org (the “Website”) and from donors, volunteers and participants in Code Tenderloin’s programs (“Programs”).
We may update this Privacy Policy from time to time. When we update it, we will post any modifications or changes to the Policy on our Website. We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Privacy Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Website prior to such change(s) taking effect.
Contacting Code Tenderloin; Reporting Violations. If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:
Code Tenderloin
Attn: hello@codetenderloin.com
55 Taylor Street
San Francisco, CA, 94102
(415) 240-2735
We are committed to resolve any complaints about our collection or use of your Personal Data. We will reply to your complaint as soon as we can, and in any event, within 45 days.
User Consent. By submitting Personal Data through our Website and/or Programs, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
A Note to Users Outside of the United States. If you are a non-U.S. user of the Website, by visiting the Website and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Purposes of Processing.
What is Personal Data?
We collect information about you in a range of forms, including Personal Data. As used in this Policy, “Personal Data” includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your Personal Data?
We will only process your Personal Data in accordance with applicable data protection and privacy laws. We need certain Personal Data in order to provide you with access to our Programs. If you submitted an application to join, or volunteer for, or donate to any of our Programs, you will have been asked to check a tick box indicating your agreement to provide this data in order to participate in our Programs. This consent provides us with the legal basis we require under applicable law to process your Personal Data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your Personal Data in line with this policy, please do not submit an application to participate in or volunteer for any Program.
Sensitive Personal Data
Subject to the following paragraph, we may ask that you send us, or disclose, Sensitive Personal Data for the purposes of administering our Programs (e.g., social security numbers, information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership).
If you send or disclose any Sensitive Personal Data to us, you consent to our processing and use of such Sensitive Personal Data in accordance with this Privacy Policy. If you do not consent to our processing and use of such Sensitive Personal Data, you must not submit such Sensitive Personal Data.
Types of Data We Collect. We collect Personal Data and Anonymous Data, as described below. When we use the term “Anonymous Data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create Anonymous Data from the Personal Data that we receive about you and other individuals whose Personal Data we collect. We make Personal Data into Anonymous Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze usage patterns in order to make improvements to our Website and our Programs.
Information You Provide to Us.
We may collect Personal Data from you, such as your first and last name, gender, race, ethnicity, military service information, housing status, disabling condition, income and sources of income, benefits, health insurance status and provider, email, home and mailing addresses, contact phone numbers, professional title and company name when you register to participate in or volunteer for our Programs.
When you donate on our Website, we will collect all information necessary to complete the transaction, but we do not process, record or maintain your credit card or bank account information and we do not store this information directly on our servers, but this information will be shared with third party payment service providers (such as PayPal and Stripe) who help process and fulfill your donation.
If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
When you participate in one of our surveys, we may collect additional profile information.
We also collect other types of Personal Data that you provide to us voluntarily, or other requested information if you contact us via email regarding the Programs.
We may also collect other forms of Personal Data, such as at other points in our Website that state that Personal Data is being collected.
Information Collected via Technology.
Code Tenderloin does not currently collect Personal Data from tracking cookies, pixels or other forms of personal or device identification on our Website.
How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Website.
Information Collected from Others. We may also get information about you from other sources, for example, if you have agreed to share information with our partners or within the IAM organization. We may receive Personal Data and/or Anonymous Data about you from companies that aid our Programs. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Website in order to improve the Programs we provide.
Use of Your Personal Data
General Use. In general, we use Personal Data you submit to us for the purposes of administering our Programs, responding to requests that you make or to aid us in serving you better. We use your Personal Data in various ways, including as follows:
If you are a participant in the Programs:
to assist you in removing employment barriers by providing you with training on job readiness, transportation needs to interviews and other advisory services;
to refer you to third party support services, including to overcome personal obstacles such as substance abuse, mental health, education levels or personal finance problems;
if you have a criminal record, to possibly refer you to Public Defenders Clean Slate Program;
to build partnerships with local businesses and major technology companies;
to aid in admittance decisions to our Programs; and
to identify you as a Program participant in our system.
For Program participants, donors and volunteers:
to improve the quality of experience when you participate in our Programs and interact with our Website;
to send you administrative email notifications, such as Program materials and timetables, support or other advisories;
respond to your inquiries, including as related to employment or volunteer opportunities or other requests;
make telephone calls to you, from time to time, for administrative purposes or to solicit your feedback; and
send newsletters, surveys, and other materials related to our Programs and for other marketing purposes of Code Tenderloin.
User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Programs. We occasionally publish such content. When we publish this content, we may identify our users by their personal information (such as first and last name, job title, photograph and age). We obtain the user’s consent prior to posting such information along with the testimonial. In addition, we may post user feedback on the Website from time to time. We will share your feedback and the information that you have consented to us to use for the purposes of displaying your feedback on the Website.
Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data for various purposes, including to analyze request and usage patterns so that we may enhance the quality of our Programs. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
Providing, Improving, Developing, and Facilitating Your Use of Our Programs. When you submit to us Personal Data, we may use it to provide, maintain, improve, and develop our Programs; measure, track, and analyze trends in connection with your use, participation, and performance in our Programs; verify your identity (e.g. through government-issued identification); complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through the legal process.
Third Parties Designated by You. When you apply to our Program(s), the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information.
Users. We will share your Personal Data with other users solely for the purpose of administering our Programs.
Third Party Support Programs. We may share your Personal Data with third party support service organizations, such as housing, employment and health services, to help evaluate your needs, and provide you assistance in meeting them, and for the purposes of assisting you to attain emotional and physical well-being, housing and employment, and for successful participation in the Programs. Information submitted on the application such as contact information, emergency contact information, age, race, gender, veteran status, income level, housing status, disability status, household size, and name may be reported to government agencies (City, County, and Federal), existing or potential funders, auditors, property managers and/or landlords, potential employers, and other community partners for the purpose of evaluation and substantiating each Program’s outcomes.
Third Party Service Providers. We may share your Personal Data with third party service providers to: improve and provide you with the Programs that we offer you; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to Code Tenderloin. These third party service providers are required not to use your Personal Data other than to provide the services requested by Code Tenderloin.
IAM. We may share some or all of your Personal Data with IAM our fiscal sponsor, or any of its participating programs, joint ventures, or other companies that assist IAM with the administration of its programs, in which case we will require IAM, our affiliated programs and third parties to honor this Privacy Policy.
Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our organization or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as an organizational asset. If another company acquires our organization, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Code Tenderloin may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Code Tenderloin; (c) to protect or defend the rights or property of Code Tenderloin or users of the Programs or Website; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Program Terms.
Third Party Websites. Our Website may contain links to third party websites. When you click on a link to any other website or location, you will leave our Website and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Your Choices Regarding Your Information. You have several choices regarding use of information on our Programs and Website:
Email Communications. We will periodically send you free newsletters and emails that directly promote our Programs. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information above). Despite your indicated email preferences, we may send you service-related communications, including notices of any.
Changing or Deleting Your Personal Data. You may change any of your Personal Data by sending an email to us at the email address set forth in Section 1 above. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
Security of Personal Data. We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us using the details in Section 1 above).
Retention. We will only retain your Personal Data for as long as reasonably required for you to use the Programs and the Website unless a longer retention period is required or permitted by law (for example, for regulatory purposes).