Last updated: July 1, 2023

Impact Badge’s core purpose is to provide an online platform that supports the Certificate and Digital Badge services of the Center of Public Safety for Women (CPSW) #StopGBV Program (each, a “Program”). This privacy policy (“Privacy Policy”) describes our policies and procedures about the collection, use, disclosure and sharing, or other processing of your personal information when you use our websites (e.g., impactbadge.org, stopgbv.org, egirlpower.org), our Impact Badge platform (e.g., impactbadge.org) (“IB”) or participate in or use our Program sites (collectively, the “Sites”), as well as when you interact with or participate in our events, programs, trainings and our other services and offerings, including services accessible through IB (collectively, the “Services”).  This Privacy Policy applies to activities by CPSW and its affiliates, subsidiaries and related entities (collectively “SGBV,” “we” or “us”), including activities that we perform for other entities through management services agreements.

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use or, if you engage with IB, then those defined in the IB Platform Terms of Use Agreement (as applicable, the “Terms”).  In this Privacy Policy, “personal information” includes references to “personal data” as defined under applicable laws. Your use of our Sites and Services, and any dispute over privacy, is subject to this Policy and the relevant Terms, including the applicable limitations on damages and the resolution of disputes.  The Terms are incorporated by reference into this Policy.

Personal Information That SGBV Collects

We collect personal information directly from individuals, from third parties, and automatically through the Sites and Services. You do not have to provide us your personal information.  However, if you choose not to disclose certain information, we will not be able to provide you with access to certain services or features, including account registration, event registration, training and certificate programs, or participation in certain aspects of our Programs.

Registration Information. We collect personal information when you register for an account, a conference or other events or programs:

IB ID, Account and Profile Information. Users may sign up for, request, or order our Services and may register to receive materials on our Sites. Personal information collected on the Sites includes community forum content, profiles, photographs, names, unique identifiers (e.g., social media handles or usernames), information about your current and past employment affiliations, contact and billing information (e.g., email address, billing address, telephone, fax), and transaction information. In order to access certain personalized services on the Sites, you may be asked to also create and store a username and password for an account from SGBV, and/or to link your IB ID account with other providers’ social accounts (such as LinkedIn, Twitter or Facebook).  Also, in order to tailor SGBV’s subsequent communications to users and continuously improve the Sites’ operations and services, SGBV may also ask users to provide additional optional information regarding their interests, demographics, experience and detailed contact preferences.

1. IB.To register for and participate in the IB platform and related Services, users must have an active IB ID and account (see above for information collected related to account registration). Depending on the Services in which users participate, we may also collect additional information relating to their use of those Services, including:

• IB Donations/Contributions: We collect information about donations made on IB. SGBV generally only records the result of the transaction and any references to the transaction record provided by the third-party site.  For example, when users make financial contributions, we collect and process the donation amount, and identifiers used to associate that donation with the donor and Program. Further, we use third-party services including Paypal to facilitate donations. If applicable, the third-party site may collect payment information directly to facilitate a transaction.
• IB Pro Bono Volunteer Hours: Users who register to participate as prospective or actual Pro Bono Volunteers may be asked to provide information, such as skills and interests, that are relevant to helping match Pro Bono Volunteers and Program participants and activities. SGBV may ask users to provide residency details in order to confirm their ability to legally participate in Pro Bono Volunteer activities. SGBV may also ask users to provide additional optional information regarding demographics and socioeconomics, for the purpose of compiling, analyzing and disclosing aggregate statistics regarding diversity of participation in Programs and communities (including in the IB platform and IB Pro Bono Volunteer opportunities), to help track progress towards meeting SGBV’s commitment to diversity initiatives.

Events Registration. When you register for one of our events (e.g., conferences and summits, whether in-person or virtual) to participate as an attendee, a speaker or a sponsor, we collect personal information that includes name, company, contact information, and other information.

Training and Certificate Registration.  When you participate in one of our training or certificate programs, we collect registration-related personal information that includes name, certificates, contact information, and other information depending on the circumstances.

Registration for Program Resources and SGBV Resources. You can register to receive access to various resources provided by SGBV and its Programs. This includes providing us with personal information such as your email address and name to receive newsletters, mailing list postings and social media postings, to view webinars, and to access other resources made available by SGBV and its Programs.

Your Content. We collect and store the information and content that you post to the Sites, including your questions, answers, comments, forum postings, and responses to surveys. Please see the section on Publicly Available Information for how the information you post will be viewed on our Sites.

Communications. When you communicate with us (via email, phone, through the Sites or otherwise), we may maintain a record of your communication.

Payment Information. To donate and/or to purchase Services (including registering for events, training and certificates), users may be asked to be directed to a third-party site, such as Paypal, to pay for their purchases. If applicable, the third-party site may collect payment information directly to facilitate a transaction. SGBV generally only records the result of the transaction and any references to the transaction record provided by the third-party site.

Automatically Collected Information. In addition, SGBV may automatically collect the following information about users’ use of the Sites or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; when you open certain emails we send; links you click; your IP address; your country of location; the length of time you visit our Sites and or use our Services; and the referring URL, or the webpage that led you to our Sites. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information.

De-identified Information. We may de-identify and aggregate certain personal information we collect such that the information no longer identifies or can be linked to a particular user or an individual data subject (“De-identified Information”), subject to the terms of any applicable user agreements. We may use this information to improve our Services, analyze trends, publish market research, and for other marketing, research or statistical purposes, and may disclose such information to third parties for these specific purposes.

Performing Services for Nonprofit Entities in a Services Relationship. For certain of its Programs that are structured as separate legal entities, SGBV performs services as a services provider. In such cases, TLF collects and processes the same types of personal information as described above, doing so in the furtherance of performing services for those Program entities.

Purposes and Legal Bases for Our Using of Your Personal Information

Purposes and Legitimate Interests

SGBV uses the personal information we collect for our legitimate business interests, which include the following purposes:

• Providing our Sites and Services. To provide the Services and our Sites (including IB and its service offerings, and Program Sites), to communicate with you about your use of our Sites and Services, to respond to your inquiries, provide troubleshooting of the Sites and for other purposes to support users and the community.
• Maintain our Training and Certificate Programs. To maintain records about who has attended or registered to attend training programs, take certificate courses and received certain certificates.
• Personalization. To tailor the content and information that we may send or display to you on our Sites and in our Services, to offer location customization and personalized help and instructions and to otherwise personalize your experiences.
• Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Programs, Services, events, trainings or other information we think may interest you related to SGBV, and, subject to applicable law, our affiliates, subsidiaries and managed services entities.
• Advertising.  For targeting advertising to you on our Sites and third-party sites and measuring the effectiveness and reach of ads and services (through third-party ad networks and services).
• Analytics.  To gather metrics to better understand how users access and use our Sites and Services and participate in our Programs; to evaluate and improve the Sites, including personalization, to develop new services; and to understand metrics regarding the community health of our SGBV. If a user voluntary provides and explicitly consents to our processing of personal information regarding their demographics and socioeconomics, we process such personal information for the specific purposes for which you have consented, which may include for the purpose of compiling, analyzing and disclosing aggregate statistics regarding diversity of participation in Programs and communities (including in IB Pro Bono Volunteer opportunities), to help track progress towards meeting SGBV’s commitment to diversity initiatives and subject to your consent.
• Compliance. To comply with legal obligations and requests. For example, to comply with laws that compel us to disclose information to public authorities, courts, law enforcement or regulators, maintain records for a certain period, or maintain records demonstrating enforcement and sublicensing of our trademarks and those of our SGBV.
• Business and Legal Operations. As part of our general business and legal operations (e.g., accounting, record keeping, and for other business administration purposes), and as necessary to establish, exercise and defend (actual and potential) legal claims.
• Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of the relevant Terms or this Privacy Policy. 

Sharing of Personal Information

We disclose personal information as set forth below, and where individuals have otherwise consented:

• Publicly Available Information, including Your Contributions to Programs. User names, other user ids, email addresses and other attribution information related to the information and contributions that a User makes. Your contributions to Programs, and certain of your other Content such as comments and messages posted to public forums, are available to other participants and users of our Programs and of our Services, and may be viewed publicly. In some cases you may be able to provide Program or contribution-related information directly to third-party sites and services; these third parties are independent data controllers and their use of your personal information is subject to their own policies.
• IB. Within IB, in addition to the other specific disclosures set forth in this Privacy Policy, we disclose certain of your information in order to enable you to receive, participate in and make use of the IB Services, including engagement with Programs and communities through IB, as set out below:
  • IB Pro Bono Volunteers. If you register with IB as a potential Pro Bono Volunteer, we make certain of your information available to Program participants as part of the evaluation for your participation as a Pro Bono Volunteer. If you are accepted to participate in Pro Bono Volunteer activities or projects through IB, we may make information related to your participation publicly available on IB pages related to that Pro Bono Volunteer opportunity.
• Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, contractors and consultants.
• Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of SGBV, whose use and disclosure of your personal information is subject to this Privacy Policy, unless an affiliate has its own separate privacy policy.
• Organizational Events. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, or restructuring of all or part of our business operations, bankruptcy, or similar event, including in negotiations, due diligence, and integrations related to such transactions.
• Event Participants. If you register for an event, we may ask for your consent to share your personal information with third party sponsors and other participants; for example, to facilitate your ability to swipe your badge or visit and interact with a virtual booth to easily sign up for or participate in activities, events and gifts offered by third parties participating in the event, or to give you the option to be listed on the attendee list that is available to other attendees, sponsors and participants.  We will not share your event information with third parties without your consent, and in particular you have the choice whether or not to permit your badge to be swiped by any third party participating in the event, or to visit and interact with a third party’s virtual booth.
• Training and Program Sponsors. If you participate in one of our certificate or training programs that a third party has sponsored or engaged us to provide to you and others (e.g., your employers), we may receive attendee list information from them and may share information about your completion of the program, including confirmation of your participation in your certificate program(s) and results, as applicable; these third parties are independent data controllers and their use of your personal information is subject to their own policies.
• Legally Required. We may disclose your information if we are required to do so by law (including to law enforcement in the U.S. and other jurisdictions).
• Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of SGBV, its Users, participants in its events or Programs, or others.
• Anonymized and Aggregated Information. We may share aggregate or De-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Cookies, Tracking, and Interest-Based Ads

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on our Site and across third party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary these activities.

• Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in, to understand how users navigate through and use the Sites, and to display personalized content and targeted ads (including on third party sites and applications).
• Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we track browsing activities. We may also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.
• Analytics Tools. We may use internal and third-party analytics tools, including Google Analytics. The third-party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

Please note that SGBV does not respond to browser “do not track” signals or other similar mechanisms intended.

Targeted Ads. We may work with third party advertisers to display more relevant ads on our website and on third party sites; these third parties may display ads to you based on your visit to our Sites and other third party sites.

Data Security

We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your passwords, phone, and computer by, among other things, signing off after using a shared computer, choosing robust passwords that nobody else knows or can easily guess, not using a password for more than one site or service, and keeping your log-ins and passwords private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.  We ask you to promptly notify us here if you become aware that any information provided by or submitted to our Sites or through our Services is lost, stolen, or used without permission.

Marketing Choices

You may opt out of or withdraw your consent to receive direct marketing emails from us by using the unsubscribe or opt out mechanisms included in our marketing emails or by notifying us here. You may also unsubscribe from mailing lists via the applicable mailing list’s subscription website or, in some cases, by using the unsubscribe mechanisms included in such emails.

Retention of Your Personal Information

We generally keep personal information only for as long as required to fulfill the purposes for which it was collected. However, in some circumstances, we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.  In specific circumstances, we may also retain your personal information for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

International

The IB platform is for U.S. citizens and residents only.

Children’s Privacy

Except as specifically indicated within a Site, we do not knowingly collect or solicit personal information from anyone under the age of eighteen (18), or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information. Where we specifically indicate that we collect personal information from children under 18, we will obtain the parent or guardian’s consent and provide adequate notice.

Links to Third Party Sites and Services

The Sites may contain links to third party sites or online services. Please refer to the privacy policies of the relevant third party websites or services to find out more about how they process and handle personal information.

Your Rights

Access and Amendment. If you have registered with us and created an IB ID profile or an IB Account wish to access or update certain personal information contained therein, you may do so online by visiting the “My Account” settings in your respective account.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request here. We may ask you to verify your California residency.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us here.

Changes to the Privacy Policy

This Policy is current as of the effective date set forth above. If we change our privacy policies and procedures, we will post those changes on this page and/or continue to provide access to a copy of the prior version. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice on our Sites or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.