Privacy Policy
The Contingent (“The Contingent,” “we,” “our,” or “us”), an Oregon nonprofit corporation, respects your privacy and is committed to maintaining and using your information responsibly. Accordingly, The Contingent has developed this Privacy Policy in order for you to understand how The Contingent collects, uses, discloses, and otherwise processes your personal information.
For the purposes of applicable data protection laws, The Contingent, with its principal address at 809 N Russell St Ste 203, Portland, OR 97227 USA, is the controller of your information. This means that we are the primary entity who decides the purposes and means for collecting and processing the personal information we collected from you.
This Privacy Policy describes how we manage the personal information that we collect at everychildarkansas.org (the ”Site”) as well as through other means. This Privacy Policy covers your use of the Site, whether you simply access and browse the Site, enter information into the Site, or use any services or other features that we may offer through the Site. The foregoing activities are collectively referred to as your “use of the Site” (or a similar phrase) or the “Activities”. Your use of the Site signifies to us that you consent to the terms of this Privacy Policy.
The Contingent follows industry standards on information security to safeguard sensitive information including strong passwords, multi-factor authentication, data encryption, and security awareness training for all team members.
Personally Identifiable Information (PII) is accessible only to staff who need it for a business purpose. Confidential data, including PII, is protected via role-based access controls to ensure that it is not improperly disclosed, modified, deleted, or rendered unavailable. Access to systems or applications that manage confidential data requires approval by The Contingent’s Data and Technology teams. All sensitive and confidential data, regardless of storage location, will be retained only as long as required for legal, regulatory, and business requirements. The Contingent team members are required to read and sign The Contingent’s Data Privacy Statement and Confidentiality Agreement which outlines best practices in this area, including protection and acceptable use of data.
If you choose to give us personal information via the Internet for the purposes of participation in foster care, volunteering, processing a donation or subscribing to our email newsletter, then it is our intent to let you know how we will use such information. If you express interest in foster care or volunteering, internships or other programming, you consent to have us share that information with our direct partners in the work—The Contingent/Every Child Affiliates, DHS, or other foster care partners.
INFORMATION WE COLLECT ABOUT YOU
We collect several types of information from and about our Site users, including:
Personal information
When you interact with us through the Site or offline, we may ask you to voluntarily provide us with personal information in order enable us to respond to you, or provide the features you use to interact with us through the Site. As used herein, personal information refers to information that identifies, relates to, describes, is associated with, or is reasonably capable of being associated with a particular individual. Some common ways you may be asked to provide personal information include when you interact with us by:
- Submitting an inquiry form through the Site, or contacting us offline, to learn more about our mission, initiatives, and activities
- Filling out an application for employment or otherwise inquiring about career opportunities
- Making a donation to The Contingent, including through the payment portal on the Site
Depending on the nature of your interaction with us, the personal information that we ask you to provide to us may include the following types of information:
- your name, home address, email address, telephone number, and other information that could be used to contact you or identify you personally
- business information, including your company, title, and business contact information
- employment history and other employment-related information if you’ve inquired about career opportunities
- payment information when you make a donation
- family or dependent identifying information, financial information, banking information, information confirming your identity and residence, and similar information for grant applications
- other types of personal information related to or required for the Activities you engage in on the Site or through your offline interactions with us.
Personal Information We Collect From Third Parties
At times The Contingent works with third parties, including federal, state, and local government agencies, to administer grant programs and carry out other initiatives in furtherance of our mission. In such cases, it may be necessary for the third parties we work with to provide us with personal information related to program participants in order for us to administer the program or initiative.
Automatically-Collected Information
We use certain digital analytics tools on the Site that help us analyze site usage and performance when you visit and use the Site. The tools we use include cookies. The information we collect automatically typically does not include any individuals’ names or contact information. Rather, as you navigate and browse the Site, these analytics tools automatically collect and store information about your visit to and use of the Site, such as: the date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol (“IP”) address, mobile device ID, type of computer or other operating device used, the actions you take on the Site (such as the web pages viewed and the links clicked), the websites (if any) from which you linked to the Site, and the website(s) you visit after visiting the Site. All such information is referred to in this Privacy Policy as “Automatically-Collected Information,” and may be considered personal information depending on applicable privacy laws.
This Automatically Collected Information allows us to better understand the visitors to the Site, where they come from, and what content on the Site is of interest to them. It also helps us to maintain the security and operation of the Site. We only ever use this Automatically Collected Information for our internal analytics purposes, to diagnose problems with our servers, and to improve the quality, performance, and functionality of the Site.
Cookies and other Technologies
The Site uses a feature of your internet browser called “cookies” to make your interactions with the Site easy and meaningful. When you visit the Site, our servers send a cookie to your computer or other operating device. The cookie is placed on your hard drive or other operating device, and it assigns your computer or operating device a unique, random number that acts as a sort of anonymous ID. Standing alone, cookies do not personally identify you; rather, a cookie identifies the computer or operating device used to access the Site. Unless you choose to identify yourself to us, such as by logging-in to your account or filling out a web form, you remain anonymous to us when browsing the Site.
Most browsers automatically accept cookies, but you can disable the acceptance of cookies at any time by changing the preferences in your browser. Most browsers also allow you to change the settings to require that the browser notify you when you receive a new cookie. Please refer to your browser for information on how to disable and control cookies. Information about managing cookies in commonly used browsers is available online from www.allaboutcookies.org. If you disable your web browser’s ability to accept cookies, you will be able to browse the Site, but you may not be able to successfully use certain features of the Site.
Our use of Google Analytics
When you visit our Site, Google Analytics may automatically collect information from you through the use of Google’s analytics IDs, and Google provides some of this information to us in aggregate and anonymized form. An analytics ID is a specific string of numbers and letters (often called a “character string”) that is assigned to your computer or device but does not name you. The analytics ID allows Google to track usage data of a website, such as date and time of visit, duration of visit, website traffic patterns, “clickstreams,” other similar information about how visitors use a website, the type of web browser used, the operating system/platform a visitor uses, IP address, the websites that referred or linked a user to a website, and your CPU speed. Google Analytics provides information about the use of our Site to us in aggregate form (i.e., data about many Site users combined and not just about you). Some of this data might include the regional location or city of Site users, but again, this data will be in aggregate (and not individual) form. [Google Analytics also provides data anonymization features which The Contingent enables for its use of Google Analytics on the Site.] We might use information we receive from Google Analytics to learn how users are using the Site in general, and to improve the Site. We will not receive the analytics ID assigned to your computer or device that you use to access and use the Site.
Information You Post Publicly
The Contingent maintains social media accounts on a variety of major social media platforms. When you interact with us on social media you may elect to provide information to be published or displayed on social media platforms that are visible to other Site users. Information which you publish may be displayed or transmitted to others at your own risk.
WHY WE COLLECT AND HOW WE USE YOUR PERSONAL INFORMATION
As described above, you may voluntarily provide personal information to us in several ways. Please note that you do not have to provide us with your personal information to browse the Site, and you are never under any obligation to provide your personal information. However, if you do not provide your personal information, you may not be able to use certain features of the Site to interact with us. When you do provide us your personal information, you are authorizing us to use that information to fulfill the purposes identified at the time of collection or herein in accordance with the terms of this Privacy Policy, and to store your information securely. You understand that your personal information may be subject to the laws of the United States, and that it may be accessible to governments, tribunals, law enforcement and regulatory agencies in the United States.
Use of Personal Information to Respond to Requests and to Contact You
The Contingent uses personal information provided by Site visitors and supporters to respond to their requests and inquiries. For example, if you request information about our mission, initiatives, and activities, we will use the information provided to contact you about your interest in The Contingent. If you make a donation or volunteer, the personal information you provide therewith will be associated with you in our supporter or volunteer database. If you apply for a job, we will use the information provided to consider you for the position and to contact you regarding your application. We may also use your personal information to contact you regarding your use of the Site and/or to provide required notices.
Use of Personal Information for Marketing Purposes
We may also use personal information provided by Users for marketing purposes. For example, if you inquire about our mission, initiatives, and activities, we may use your personal information that you provide to contact you to further discuss your interest in The Contingent, and to send you information regarding The Contingent, which may include information about initiatives or events. At any time, you may request that we stop contacting you for marketing purposes by sending an email with your request to info@thecontingent.org. If you request that we not contact you for marketing purposes (either by using the unsubscribe mechanism or by sending us an email), depending on the nature of our business relationship with you, we may still contact you for non-marketing purposes relating to your use of the Site or otherwise in regard to our business relationship with you.
Use of Personal Information and Automatically-Collected Information Generally
We also may use both personal information and Automatically-Collected Information to help diagnose problems with the Site, to analyze statistical use patterns and demographic data, and to improve our Site and user experience on the Site. We may use your personal information and Automatically-Collected Information to customize and tailor your experience using the Site, displaying content we think you might be interested in and according to your preferences.
WHO DO WE SHARE YOUR INFORMATION WITH?
The Contingent may share your personal information in the manners described in this section. In addition, we may also share aggregated Automatically-Collected Information that has been de-identified or otherwise rendered anonymous without restriction.
Third-Party Service Providers
The Contingent may provide your personal information and Automatically Collected Information, including in some cases payment information, to third party service providers to perform certain services for us. In some circumstances, The Contingent will provide personal information directly to the service provider, while at other times you may provide your personal information to the service provider by using certain features on the website. We may disclose personal information to third party service providers for reasons including, but not limited to:
- performing certain marketing on our behalf, such as through promotional e-mail campaigns or a newsletter;
- to provide a secure online payment portal;
- performing website analytics services, as described above in this Privacy Policy; and
- providing other services relating to the operation of the Site (such as hosting, data storage, and security).
These third parties may include: DHS or another state government agency with direct responsibility for oversight of one or more activities you express interest in, partners of The Contingent (affiliates or partner organizations) responsible for next steps in relation to your expressed interests (in foster care, internships, grant-related programs, scholarships, etc.).
The Contingent does not sell User personal information to any third parties. Rather, any disclosure of personal information to third party service providers is solely to enable the service provider to perform the requested services on our behalf. These third-party service providers are not authorized to use your information received from The Contingent in any way, including for their own marketing efforts, other than for the purpose of providing a service on our behalf.
Merger, Acquisition, or Sale
We may transfer any and all personal information and Automatically-Collected Information to a third party if The Contingent is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of Users is among the assets transferred. Any new information you provide to a successor in interest after the transfer will likely be subject to a new policy, and you should review that policy.
Required by Law
Notwithstanding anything to the contrary in this Privacy Policy, The Contingent reserves the right to disclose your personal information and Automatically-Collected Information, without your consent and without additional notice to you, if we reasonably believe we are required by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process to do so; if we reasonably believe that disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud. For the avoidance of doubt, at times The Contingent may work with federal, state, and local government agencies (“Agencies”) to administer grant programs, including the disbursement of funds. In such cases, and under such programs, The Contingent may be required by law or agreement to disclose personal information of program participants to such Agencies.
RETENTION, SECURITY, AND Compliance
How long do we keep your personal information?
We keep personal information for as long as necessary to meet the business purposes for which we’ve collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate length of time for retaining personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information, and whether we can achieve those purposes through other means, along with any applicable legal requirements.
Security of your information
We have put in place commercially reasonable security measures to reduce the risk of your personal information being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we use reasonable means to limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any personal information or Automatically-Collected Information provided to us in connection with your use of the Site or when you interact with us.
“Do Not Track”
The Site does not track your online activities over time and across third-party web sites or online services, and so does not respond to browser “Do Not Track” signals. As described below, the Site may contain links to other websites not owned or operated by The Contingent. These websites may set cookies that obtain information about the fact that a web browser visited the Site from a certain IP address. These websites are not authorized to collect any other personal information from the Site unless you provide it to them directly.
Third Party Links on the Site
The Site may contain links to, or embedded code from, other websites not owned and operated by The Contingent, for example, social media platforms such as Facebook, Twitter, Instagram, and LinkedIn. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our Site, or click on embedded content from another site, we encourage you to read the privacy notice of the third party site or content provider.
Children’s Privacy
We do not knowingly collect personal information from children under the age of 16. If we learn that we are in possession of personal information collected from a child under the age of 16, we will immediately delete that information from our systems.
Age Limits for Receive-Only Users
The age limit for Receive-only end users is 13 years old.
Bank Account Information and Credit Transfers
For all applicable use cases involving the transfer of funds, The Contingent collects users’ bank account information, including but not limited to end user contact information, account and routing numbers. The Contingent collects and shares this information with our service provider, Dwolla, in order to initiate credit transfers to Receive-only Users. Dwolla’s Privacy Policy is available here.
Your California Privacy Rights
Please note that The Contingent does not sell or disclose personal information to third parties for their direct marketing purposes. Notwithstanding the above, if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties. Specifically, California law provides you the right to submit a request to us to receive the following information:
- the categories of information we disclosed to third parties for such third parties’ direct marketing purposes during the preceding calendar year;
- the names and addresses of third parties that received such information; and
- if the nature of a third party’s business cannot be reasonably determined from the third-party’s name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.
Changes to this Privacy Policy
We may review and amend this Privacy Policy from time to time to take into account changes in law, technology, and our operations. We will post any changes to this Privacy Policy on the Site. You can determine if this Privacy Policy has been revised since your last visit to the Site by referring to the last updated date at the top of this Privacy Policy. Please periodically review this Privacy Policy before using the Site, as continued use of the Site signifies to us your acknowledgment and understanding of any changes. All personal information held by us will be governed by the most recent Privacy Policy posted on the Site. If we intend to use earlier-collected personal information and Automatically-Collected Information in accordance with the terms of the revised Privacy Policy and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will provide you notice or request your express consent prior to such use.
— Last Updated: December 16, 2022
