I. Introduction


This Privacy Policy explains how The Colorado Trust (“The Trust” or “We”) collects, uses, shares and safeguards Personal Data and Non-Personal Data on www.coloradotrust.org, mobile websites and any other digital services and platforms officially operated or used by The Trust from time to time (“Sites”). We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the "Effective Date" at the bottom of this page.

II. Types of Data We Collect


Personal Data
We collect information that enables The Trust to identify or contact you (“Personal Data”) to carry out its nonprofit mission. Sites collect this information for a variety of business reasons, including but not limited to registering for a Trust event or program, or otherwise interacting with The Trust.


The types of Personal Data we collect include, but are not limited to:

  • General data (e.g., names, home and business addresses, email addresses, internet protocol (IP) addresses and mobile/landline business/personal telephone numbers that are provided by our members/customers)
  • Professional data (e.g., organization names, job titles)

Non-Personal Data
We collect information that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to:

  • Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site)
  • Products and services viewed
  • Computer type, operating system and platform type


III. How We Use Your Data


In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:

Personal Data

  • Identify you when you visit our Sites
  • Provide service communications (e.g., program registrations, customer service messages)
  • Provide information and services you request or that we think you may be interested in
  • Respond to your emails or online requests for services or information
  • Deliver and process surveys
  • Personalize and improve the usability of the Sites

Non-Personal Data

We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select a link that takes you to sites not operated by The Trust, you may be subject to the privacy policies of these third-party sites.


IV. How We Share Your Data


We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:

  • Share data with third parties as required by law or to protect The Trust in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on The Trust; (b) protect and defend The Trust’s rights or property; or (c) protect the personal safety of Trust personnel or members of the public in appropriate circumstances.
  • Share data with third parties under other unanticipated situations, but only with your consent.

V. How You Can Manage the Processing of Your Data

You can manage your profile and email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below. For California residents, please consult the “California Privacy Rights” section for additional considerations.

Our processing of your data is based upon your consent, contract performance (e.g., your purchase of services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.

VI. California Privacy Rights


In addition to the rights as explained in this Privacy Policy, under California’s "Shine the Light" law, California residents who provide personal information (as defined in the statute) to obtain products or services for personal, family or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information, please write to us at: The Colorado Trust, Attn: Website Manager, 1600 Sherman Street, Denver, CO 80203. Please include your full name and address.

VII. Canada Anti-Spam Law


The Trust complies with the Canada Anti-Spam Law. Site visitors who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.

VIII. Children

We do not knowingly collect Personal Data from or market to children under the age of 13.

IX. How We Protect Personal Data


The Trust implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Except for the sharing of information as set forth in this Privacy Policy, we restrict access to Personal Data to certain companies who need the data to operate, develop, or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Unfortunately, no data transmission over the internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use or disclosure, The Trust cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from our online Sites. If you have questions about this Privacy Policy, please contact us at questions@coloradotrust.org.

X. Linking to Other Internet Sites


You should be aware that other internet sites that are linked from the Sites or from a Trust email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications or other digital platforms.

XI. Cookies and Other Web Devices

Our website sends cookies (e.g., pieces of code or text placed on your computer by us or third parties when you browse our Sites) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Sites. Cookie settings can be controlled in your internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our Sites. If you do not allow cookies, some features and functionality of our Sites may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software), internet protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.


XII. Transmission of Data to Other Countries


Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.


XIII. Right to Complain to Supervisory Authority


You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.


XIV. Breach Notification


In the event we determine the occurrence of a data security incident, we will notify you by email, U.S. mail, telephone or other means as permitted by law.


XV. Contact Information


If you have questions, comments or complaints concerning our privacy practices, or if you wish to change, access or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.

The Colorado Trust
Attn: Website Manager
1600 Sherman Street
Denver, CO 80203
questions@coloradotrust.org

Effective Date: August 2018