Privacy Policy

Last Updated: May 25, 2018

UPWARD – Uniting Professional Women Advancing Relationships and Development (“UPWARD,” “we,” “us,” or “our”) is a non-profit corporation dedicated to creating a collaborative forum for the education and advancement of senior- level professional women. We value your relationship with us and are committed to protecting your online privacy. This Privacy Policy explains how we collect, store, and use information obtained when you visit our website at www.upwardwomen.org (the “UPWARD Website”). By visiting and using the UPWARD Website, you acknowledge that you have read, understood and agreed to be bound by the terms of this Privacy Policy. UPWARD may update this Privacy Policy from time to time, and your continued use of the UPWARD Website is deemed to constitute your acceptance of any updated terms. We will notify you of any material changes to the Privacy Policy as required by law.

How We Collect and Use Information

Personally Identifiable Information. UPWARD is the controller and processor of personally identifiable information (“Personal Information”) collected through the UPWARD Website. We collect Personal Information that you choose to provide to us. Although you can visit many pages on the UPWARD Website without providing any Personal Information, you must provide certain Personal Information to apply for UPWARD membership and receive members-only communications from us.

When you apply to join UPWARD through our sign-up form on the UPWARD Website, we collect the following Personal Information:

· Name

· Company

· Job Title

· E-Mail Address

· City

· State (US only)

· Country

· Sign-up Comments (optional)

You may also provide Personal Information to us in other ways on the UPWARD Website, including when you send us e-mail or register on-site at one of our events.

Purpose of Processing. Our purpose in collecting and processing Personal Information from you is to provide you with access to members-only information, events, networks, and other UPWARD programs and services. From time to time and only with UPWARD’s prior written consent, as part of the services we provide our members, we may share Personal Information with our sponsors to permit them to use the Personal Information to contact UPWARD members and offer professionally relevant programs and services. Sponsors with whom we share Personal Information are obligated to use that Personal Information in a manner consistent with the terms of this Privacy Policy, and only for the explicit purposes authorized by UPWARD. We only collect Personal Information to the extent necessary to fulfill our stated purposes under “How We Use and Share Your Information.”

The UPWARD Website is not intended for use by, and does not knowingly collect information from, anyone under 13 years of age. No one under the age of 13 is allowed to subscribe to the UPWARD Website or otherwise provide Personal Information to us.

Non-Personally Identifiable Information. We may also passively collect information from you that is not personally identifiable information (“Other Information”) when you visit the UPWARD Website, including:

· Your web browser and operating system

· Your IP address

· The domain name of your Internet service provider

· The date and time of your UPWARD website visit

· Other technical information about your use of the UPWARD Website collected through cookies, web beacons, and other standard web tools

By passively collecting this Other Information from you and other UPWARD Website visitors, we can understand overall usage trends of the UPWARD Website and better ensure its consistent performance.

How We Use and Share Your Information

UPWARD’s mission to support the education for advancement of senior-level professional women hinges on building and maintaining a trusted relationship with you. In collecting Personal Information and Other Information, our goal is to provide you with the best possible access to the UPWARD Website and benefits of UPWARD membership. When we use your Personal Information and Other Information, we do so only to perform a contract we have entered into with you or to further our legitimate interests to grow and maintain our business (or the legitimate interests of a third party), in each case provided that your interests and fundamental rights do not override those interests.

In furtherance of this mission, we may share your Personal Information or Other Information with third parties without further notice to you in the following circumstances:

Third-Party Service Providers. We may contract with third parties to help us host and maintain the UPWARD Website, send members-only e-mail communications, and provide other services that support UPWARD operations. In each case, we will share Personal Information and Other Information only to the extent necessary to enable the third party to provide the agreed-upon support services.

Sponsors. As described above in the “Personally Identifiable Information” section, we may permit sponsors to use Personal Information for the limited purpose of offering professionally relevant programs and services to UPWARD members. For example, if you attend an UPWARD members-only event and give consent to be contacted by a sponsor of the event, the sponsor may communicate directly with you after the event regarding professional networking and other engagements specific to that sponsor’s organization. We will maintain an up-to-date record of the names and contact details of all sponsors who process your Personal Information, in written or electronic form, and will provide this record upon request.

As Required by Law. UPWARD may also share Personal Information and Other Information where disclosure is required by law or is necessary to prevent fraud, to protect your personal safety or that of the public, or to protect the legal interests of UPWARD, UPWARD members and any relevant third parties.

In Connection with a Merger or Other Transaction. In the event that UPWARD undergoes a merger, asset transfer, reorganization, or other business transaction, the entity involved in such transaction will receive access to your Personal Information as our successor and will be obligated to comply with this Privacy Policy in connection with its use of your Personal Information.

Your Control over Information Sharing

You may choose not to submit Personal Information to the UPWARD Website, but doing so will prevent you from receiving members-only information about UPWARD programs and services. You can also unsubscribe from our e-mails anytime by clicking the opt-out link or following other instructions included in each e-mail we send. After unsubscribing, you will be removed from our e-mail database and your UPWARD membership will be cancelled. Please allow up to 10 business days to process your request. After unsubscribing, you may still receive e-mail messages about the status of your account, to resolve technical issues, or to confirm a new subscription.

You may also prevent collection of certain Information by adjusting your web browser’s privacy settings to block websites from setting cookies. Blocking cookies may limit your experience on the UPWARD Website.

Residents of the European Union (“EU”) have additional rights relating to their Personal Information. Please see “Your EU Privacy Rights” below for more information.

“Do Not Track” signals. “Do Not Track” is a feature of some web browsers, including Firefox, Internet Explorer, and Safari, that allows users to control the tracking of their browsing activities across websites. Because the UPWARD Website does not track your browsing activities on other websites, it does not respond to browsers’ “Do Not Track” signals.

Your California Privacy Rights

If you reside in California, you may request information about our disclosures of your Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us by e-mail at info@upwardwomen.org.

Within 30 days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties for direct marketing purposes (if any) during the immediately preceding calendar year, along with the names and addresses of such third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted other than as specified in the above paragraph.

Your EU Privacy Rights

Residents of the EU have certain rights afforded to them by the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”).

Transfers out of the European Economic Area. We are based in Saratoga, California and the UPWARD Website is hosted by a third party that is also based in the United States. Accordingly, when you provide Personal Information and Other Information to us, it is transferred outside of the European Economic Area (“EEA”). To ensure an adequate degree of protection is afforded to your Personal Information when it is transferred outside of the EEA, we only transfer your Personal Information to countries, such as the United States, that have been deemed to provide an adequate level of protection for personal data by the European Commission. Should the European Commission revoke its adequacy decision authorizing transfers to the United States or any other country to which we transfer Personal Information, we will ensure an alternate, GDPR-compliant certification mechanism is in place.

Your legal rights. You have the right to:

· Request access to your Personal Information. We will send you a copy of your Personal Information that we have on record, which will enable to check that we are lawfully processing it.

· Request correction of the Personal Information that we hold about you.

· Request erasure of your Personal Information. As noted above, this will result in the termination of your UPWARD membership, as UPWARD must use Personal Information to provide services to its members.

· Object to processing of your Personal Information where we are relying on a legitimate interest of ours or a third party. You may object on grounds that you feel it impacts your fundamental rights and freedoms, or on grounds that we are using your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms.

· Request restriction of processing of your Personal Information. You may make this request (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

· Request the transfer of your Personal Information to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of these rights, please contact us as provided below. We may need to request additional information from you to help us confirm your identity. Typically, you will not have to pay a fee to access your personal data. However, we may charge a fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request. We try to respond to all legitimate requests within one month. It may take us longer to respond to your request if your request is particularly complex or you have made multiple requests. In this case, we will notify you and keep you updated.

Data Retention

We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, namely, to provide you with the benefits of being an UPWARD member. Periodically, we delete Personal Information of persons who are no longer UPWARD members, retaining only enough Personal Information to ensure that persons who have opted out of UPWARD communications are not opted back in to receive such communications.

Privacy By Design

UPWARD is committed to prioritizing the protection of Personal Information that it controls and processes. In line with this commitment, we will identify and address data protection constraints before undertaking any projects or providing any services that involve the use of Personal Information, and continue to consider data protection considerations while completing these projects or providing these services.

Updates to the Privacy Policy

This Privacy Policy may be amended or updated to ensure continuing compliance with all data protection regulations. Whenever significant changes to the Privacy Policy are implemented, we will communicate such changes to all persons whose Personal Information we control, including all UPWARD members.

Security

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of Personal Information, we have put in place physical, electronic, and administrative procedures to protect the Personal Information we collect online. No data transmission over the Internet, however, can be guaranteed to be completely secure. While we strive to protect your Personal Information, the UPWARD cannot completely ensure or warrant the security of Personal Information you provide to us through the UPWARD Website.

Data Breach Notification

In the event of any suspected data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so. For EU data subjects, we shall notify the competent supervisory authority of any data breach that is likely to result in a risk to the rights and freedoms of natural persons within 72 hours of the breach, or else accompany our notification with reasons for the delay. This notification shall describe the nature of the Personal Information at risk, including the categories and approximate number of data subjects concerned, the name and contact details of the data protection officer, the likely consequences of the breach, and the measures taken to address the breach. We will also notify you without undue delay of any data breach that is likely to result in a high risk to your rights and freedoms.

Links To Other Websites

This Privacy Policy applies solely to the collection and use of Personal Information and Information as provided on the UPWARD Website for use by UPWARD. The UPWARD Website may contain links to other, unaffiliated websites that UPWARD does not operate or control. UPWARD is not responsible for and cannot control how these other websites protect your online privacy. We encourage you to review the privacy policy of any website you visit, particularly one that requests personally identifiable information from you.

Contact Us

If you wish to make changes to any Personal Information you have provided to us, or would like to exercise any of your privacy rights, or if you have any questions or comments regarding this Privacy Policy, please contact info@upwardwomen.org.

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