Privacy Statement

LAST REVISED ON: OCTOBER 16, 2023

This privacy policy (“PrivacyPolicy”) is designed to help you understand how Dublin Partnerships in Education (“Nonprofit,” we,” “our”, or “us”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.

By registering for, downloading, accessing or using any part of the Services (as defined below), you accept and agree to this Privacy Policy, whether or not you are a registered user or have an account. You should not use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

SCOPE
PERSONAL INFORMATION WE COLLECT
HOW WE USE PERSONAL INFORMATION
HOW WE DISCLOSE INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
SECURITY OF INFORMATION
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
CHILDREN’S INFORMATION
OTHER PROVISIONS
CONTACT US

1. SCOPE

This Privacy Policy applies to personal information processed by us via our website, our mobile application, technology and related services, and our other online or offline offerings. To make this Privacy Policy easier to read, our website, mobile application, technology and related services, and other offerings are collectively called “Services.”

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Account Creation. We may collect information when you create an account, such as your full name, email address, mailing address, phone number, and password.
Information Provided Through the Services. We may collect any information you provide through the Services, such as any information that you voluntarily choose to provide through use of the Services. Such information which you voluntarily provide may include your name, mailing address, telephone, and email address and your child or children’s name, age, grade level, physical characteristics or descriptions, racial or ethnic origin, sex, gender identity or gender expression, medical information, and health insurance information.
Payments. We may collect information when you choose to make a purchase that requires a fee or make a donation or contribution. To complete such purchase or donation or contribution, you will be required to provide your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by our third-party payment processors pursuant to the terms and conditions of their privacy policies and terms of use, and we do not obtain access to any Payment Information in connection with your purchases or donations/contributions. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party payment processor for purposes of processing your payment to us.
Your Communications with Us. We may collect personal information, such as your name, email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Conferences and Other Events. We may collect personal information from individuals when we attend conferences and other events.
Social Media Information. We may have pages on social media sites like Instagram, Facebook, and Twitter. When you interact with our social media pages, we may collect personal information that you elect to provide to us, such as your contact details.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services.

For example, we may log your geolocation data and internet or other electronic network activity information such as IP addresses, mobile carrier, unique device identifier, device model, operating system type, browser type, browser history, browser language, links clicked, pages you viewed, how long you spent on a page, access times and information about your use of and actions on the Services as follows:

Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
Cookies. Cookies are small text files placed in device browsers or mobile devices that store preferences and facilitate and enhance your experience.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular page. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services and applications and tools that are required to identify irregular website/app behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below); and
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools (such as Google Analytics) to process analytics information on our Services.
Social Media Platforms. Our Services may contain social media buttons such as Twitter, Instagram, and Facebook (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations such as analytics providers.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use personal information to provide you with our Services, such as:

Managing your information and accounts;
Enabling you to use our Services, including enabling your children to use the offerings you purchase from us through the Services;
Operating and maintaining the Services, including the offerings you purchase from us through the Services;
Providing access to certain areas, functionalities, and features of our Services;
Processing and verifying your purchases and/or donations/contributions in our Services.
Answering requests for customer or technical support; and
Communicating with you about your account, purchases, donations/contributions, activities on our Services (including your children’s activities during the offerings you purchase from us through the Services), and policy changes.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, planning future fundraising activities and events, communicating regarding funding needs, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring and analyzing use of and interest and engagement in our Services;
Improving, upgrading, or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to analyze our user base, products and services, and trends and traffic and to provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns and non-targeted advertising.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use personal information for other purposes as requested by you or as permitted by applicable law.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell personal information.

We disclose personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share personal information are described below.

Service Providers. We may share personal information with our third-party service providers who use that information to help us provide or improve our Services (including our offerings that you have purchased from us through the Services) and/or who create, deliver and assess our advertising or marketing campaigns. This includes service providers that provide us with IT support, hosting, cloud services, event and activities software and mobile applications (i.e. Active Network, LLC), web analytics, marketing services, payment processing, email communication software, customer service, teaching, instruction, or other educational services, and other related services.
Affiliates. We may share personal information with our affiliates.
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law, law enforcement, national security requests, and legal process, such as a court order or subpoena; protect your, our, or others’ (including your children’s) rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, personal information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

D. Disclosures With Your Consent

We may share personal information you have shared to external parties for other purposes pursuant to your consent or at your direction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about personal information you have shared are determined by applicable law and are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have purchased or donations/contributions you have made. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to this Privacy Policy).
Push Notifications. We may send you push notifications through the Services. You may opt out from receiving these push notifications by changing the settings on your device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain browsers and mobile operating systems. Please note that we do not respond to or honor DNT signals or similar mechanisms that automatically communicate your choice not to be tracked online.
Technologies. You may stop or restrict the placement of certain Technologies (such as cookies) on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly.
Mobile Devices. Your mobile device may include a feature that allows you to opt out of some types of targeted advertising (“Limit Ad Tracking” on iOS and “Opt out of Interest-Based Ads” on Android). Please note that we do not engage in cross-context behavioral advertising or targeted advertising.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another entity (the “right of data portability”);

Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

Request Deletion of your personal information;

Request Restriction of or Object to our processing of your personal information; and

Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF INFORMATION

We take steps to ensure that personal information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us. We have taken appropriate safeguards to require that personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard personal information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services (including the offerings you have purchased), resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information of residents of California.

We are not subject to the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”) because those laws apply only to for-profit entities, and we are a 501(c)(3) nonprofit. Nevertheless, we choose to protect privacy of California residents so have provided the information below.

The CCPA provides California residents with the right to know/right to access what categories of personal information Nonprofit has collected about them and whether Nonprofit disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Privacy Table via Categories

The categories of sources from which we collect personal information and our business purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Personal Information” above, respectively.

“Sales” or “Sharing” of Personal Information under the CCPA. Nonprofit does not “sell” personal information or “share” personal information for cross-contextual behavioral advertising (as those terms are defined under the CPPA), nor do we have actual knowledge of any “sale” or “sharing” of personal information of minors under 16 years of age.

Profiling and Targeting Advertising. Nonprofitdoes not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Nonprofit also does not engage in cross-context behavioral advertising or targeted advertising.

Additional Privacy Rights for California Residents

Right to Know and Data Portability: The right to request that we disclose to you the personal information we collect, use, or disclose about you, and information about our data practices as well as the right to obtain a copy of your personal information.

Right to Request Correction: The right to request that we correct inaccurate personal information that we maintain about you.

Right to Request Deletion: The right to request that we delete any or all of your personal information that we have collected from or about you, subject to certain exceptions. Please note that we may not delete your personal information if it is necessary to:

Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

Debug products to identify and repair errors that impair existing intended functionality;

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

Comply with a legal obligation; or

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of “Sale” or “Sharing” of Personal Information: The right to opt-out of the “sale” or “sharing” of your personal information. Please note that we do not “sell” personal information or “share” personal information for cross-context behavioral advertising.

Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.

Rights Relating to Sensitive Personal Information. Nonprofit does not collect or process your sensitive personal information without your consent. You may choose to provide us with certain information that is considered “sensitive” under the CCPA, including but not limited to, race, ethnicity, financial account information, health information, and login and credentials. We only use this information as necessary to:

provide the Services to you (including providing our offerings you have purchased to your children);

to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;

to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions;

to ensure the physical safety of natural persons;

for short-term, transient use;

to perform services on behalf of our operations, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;

to verify or maintain the quality or safety of our products, and to improve, upgrade, or enhance the products or features offered by us; and

to collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

By providing such information to us, you consent and agree that we may store, process, and use such information to provide the Services and as set out above or as otherwise allowed by the CCPA. We do not process sensitive personal information for the purposes of inferring characteristics about a consumer. You can also choose to remove or edit content that you have chosen to share to the Services that may include sensitive personal information at any time.

Exercising Your Rights. If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Appeals. You may have the right to appeal a decision we make relating to requests to exercise your rights under the CCPA. To appeal a decision, please send your request to us at the contact information set forth in “Contact Us” below.

Your Other California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. Please note that we do not share your personal information with any third parties or affiliates for their direct marketing purposes.

10. CHILDREN’S INFORMATION

The Children's Online Privacy Protection Act of 1998 and its rules (“COPPA”)

We are not subject to COPPA because that law applies only to for-profit entities, and we are a 501(c)(3) nonprofit. Nevertheless, we choose to protect the privacy of children under the age of 13 within the spirit of COPPA.

We do not knowingly collect information directly from children under 13 years old (or other age as required by local law) through the Services. Children under the age of 13 (or other age as required by local law) are not permitted to create accounts or directly provide personal information through the Services. Only parents and guardians are permitted to create accounts and provide personal information through the Services about their children. Any personal information about children collected from and provided by parents and guardians is limited to what is reasonably necessary for the child to participate in the products or services and other offerings purchased from us by the parent or guardian and such information is solely used and shared for the purpose of providing and/or improving the Services and our other products or services and offerings you have purchased from us through the Services, in event of merger or acquisition, or as legally required, as set out in the “How We Disclose Information” section of this Privacy Policy.

We do not “sell” personal information of children or “share” personal information of children for cross-contextual behavioral advertising.

At any time, you may review your child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using your child’s information. You may contact us as described in “Contact Us” below to exercise any of these items.

If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

The Student Online Personal Information Protection Act (“SOPIPA”)

The Services are designed and operated to comply with SOPIPA. Among other things, the Services do not use data from K-12 students for targeted ads, we do not create advertising profiles for K-12 students, we do not sell or rent information of K-12 students, we use and disclose K-12 student information solely for providing and/or improving the educational products and services purchasing through the Services, in event of merger or acquisition, or as required by law, and we will delete information upon request if you contact us as described in “Contact Us” below.

11. OTHER PROVISIONS

App Stores. Your app store (e.g., Apple App Store or Google Play) may collect certain personal information in connection with your use of the Services. We have no control over the collection of such information by the third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

Third-Party Websites/Applications. The Services may contain links to or incorporate other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect. We encourage you to periodically review this page for the latest information on our privacy practices.

12. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Dublin Partnerships in Education

6379 Clark Avenue, Suite 200

Dublin, CA 94568

Or via email at info@dpie.org

Or via phone at 925 587 5610