PRIVACY NOTICE
Last Updated: October 1, 2024
Introduction
This Privacy Notice (“Privacy Notice”) applies to Transforming Research into Action to Improve the Lives of Students, a 501(c)(3) nonprofit charitable organization, (“TRAILS”, “we”, “us”, “our”), and describes how we collect, use, protect, and disclose Personal Information collected when you when you visit our Website (https://trailstowellness.org/); (opens in a new window) register and/or participate in a training, conference, focus group, study, or other program offering; through your participation in research, surveys, focus groups, studies, and questionnaires; engage with TRAILS regarding its operation and training and program offerings; and any other situations when you choose to share your Personal Information with us (collectively, the “Services”).
TRAILS believes in transparent, respectful, lawful use of Personal Information (defined below). We do not buy or sell individuals’ Personal Information, nor do we share Personal Information for targeted advertising with third parties (and have not done so in the preceding 12 months or otherwise). We treat Website visitors, program participants, trainees, and donors —and their data—the way we would like to be treated. We only collect the information that we need to run our organization efficiently and effectively and improve your experience. We do not collect, or ask any third party to collect, non-anonymized information about individuals without their knowledge and consent. By visiting the Website or otherwise providing information to us through the Services, you are consenting to the terms of this Privacy Notice, as well as our Terms of Use (opens in a new window). If you do not agree to the terms of this Privacy Notice or our Terms of Use, please do not use the Website or any other of our Services.
This Privacy Notice is not a contract and does not create any contractual rights or obligations.
1. What Types of Personal Information We May Collect
For purposes of this Privacy Notice, “Personal Information” means any information directly or indirectly relating to an identified or identifiable individual. Personal Information may not include de-identified or aggregate information, certain publicly available information, or information covered by other legal frameworks.
Exmples of information we collect are:
- Contact information: Name, nickname, mailing address, email address, phone number, school/district
- Demographics: Gender, language preference, sexual orientation, educational history, race, ethnicity, employment information, household information, national origin
- Training and implementation information: Registration information, trainings/courses taken, survey/interview/focus group data, program evaluations, program implementation data, usage of online resources
- Business and employment information: Business contact information, department, job title / description / role
- Log-in credentials: Username and password, if you chose to create an account with us
- Social media information: Username, biography, and other information that you chose to publicly share on social media networks
- Technical details: Internet Protocol (IP) address, geolocation information, information about your browser and operating system, browser settings, language settings, dates and times of connecting to a website, cookies, usage data
Additionally, we may collect any other information that you choose to share with us.
2. How We Collect Personal Information
We may collect Personal Information using the following methods:
- Directly from you when you provide it to us. This includes Personal Information you enter into forms; that you provide in phone calls, video conferences, and in-person meetings; when you subscribe to email newsletters from us; when you sign up to receive information about our work, programs, initiatives, or events; when you communicate with us via email or in writing; or when you make a donation.
- Through your participation in training, conferences, research, and surveys, whether conducted by us or our vendors or business partners.
- From references or sources that you provide or are publicly available online or in other formats.
- Automatically through tracking technologies (such as cookies, web beacons, or log files), including over time and across third-party websites or other online services.
For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see Section 7 below.
3. How We Use Personal Information
We may use your Personal Information for the following purposes:
- Communicating with you.
- Providing you with or otherwise facilitating the Services.
- Authenticating use, detecting potential fraudulent use, and otherwise maintaining the security of the Services.
- Developing, testing, and improving the Services.
- Creating and maintaining a customer relationship management system.
- Carrying out our legal and contractual obligations and enforcing our rights, including tax preparation, billing, and grant participation.
- Processing donations, issuing tax receipts, and analyzing giving patterns.
- Anonymizing and aggregating information for analytics, quality assurance, and reporting.
- Administering, registering, or enrolling you in, or facilitating your participation in the Services; surveys or questionnaires; or any other services, events, or activities sponsored by us or third parties, or offered in connection with the Services.
- Training and quality assurance.
- For any other purpose with your consent.
4. How We Disclose Personal Information
We may disclose Personal Information:
- To affiliates and other entities participating, funding, administering, and/or auditing the Services, as well as their employees and agents.
- To third parties with whom you choose to share content regarding the Services.
- With background check providers and/or consumer credit reporting agencies.
- To third party service providers (which may include, for example, donations processor(s), fraud screening providers, analytics providers, hosting providers and other third-party service providers) to help us operate the Services and administer certain functions, services, or activities on our behalf.
- When you use a third-party feature in our Website. This may include social media networks when you share content through those networks or use a social media account to log in to our Website.
- To enforce or apply our Terms of Use and other agreements or comply with any court order, law, or legal process, including government or regulatory requests.
- To advisors, consultants, auditors, or similar professionals to assess our business, financial, and legal obligations, or operations.
- If we believe it is necessary to protect the rights, property, or safety of TRAILS or others.
- For any other purpose disclosed by us when you provide Personal Information.
- With your consent, such as when you choose to provide your information to third parties.
5. How We Protect Personal Information
We implement security safeguards to protect your Personal Information. We take steps to secure Personal Information through administrative, technical and physical safeguards designed to protect against the risk of accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password or other authentication means, you are responsible for keeping it confidential.
6. How We Retain Personal Information
We will retain your Personal Information only for as long as is reasonably necessary for the purposes set out on this Privacy Notice; for as long as your account is active (i.e., for the lifetime of your TRAILS user account); as needed to provide the Services to you; and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this Privacy Notice.
7. How We Use Cookies
a. What Are Cookies?
A cookie is a small file that can be stored on your computer or mobile device by TRAILS or by third parties when you use the Website. Cookies collect data that includes “Personal Information.”
b. Types of Cookies
Cookies can be in the form of session cookies or persistent cookies. Session cookies are deleted from your computer or mobile device when you close your browser. Persistent cookies will remain stored on your computer or mobile device until deleted or until they reach their expiration date.
Browser Independent cookies, such as local and/or session storage and interaction requests, store certain data on your computer or mobile device with no expiration date. Despite the fact that these requests do not set any cookies, they can still transfer information to first or third parties.
c. Source of Cookies
First Party (TRAILS): First party cookies are set by TRAILS and can only be read by the Website. They are commonly required for the Website to function.
Third Parties: Cookies may be set by third parties, such as analytics and advertising companies. These cookies get re-read during visits to other websites if the other websites also do business with these companies.
d. Categories of Cookies
We use cookies on our Website for the following purposes:
- Essential: Some cookies are strictly necessary, and we use them in order for the Website to function, for example to ensure you can move around and use our Website effectively. They are only set in response to your actions when you request services, such as cookies that enable you to log into secure areas of the Website.
- Performance/Functionality: Cookies, web beacons, and IP address logs allow us to measure and improve the performance of our Website. For example, we may collect information in the aggregate to give us insight into how the Website is being used, such as what website you came from, what pages of the Website you visit, how long you were on the Website, and what type of browser you are using. We also may use these cookies to serve new and different content and to test new features. Web beacons may also be included in our emails to determine when and if such emails are opened or forwarded.
- Personalization: These cookies allow us to recognize you when you visit the Website, personalize your experience, and generally to serve you better. For example, if you enter your name, address or ZIP / postcode into a web form, it may be stored in a cookie so you do not have to enter it again on other forms on the Website.
- Advertising: This information may be associated with other information or combined with information from other sources, including information these third parties might track about your online activities over time and across the Internet. Third parties use this information to provide interest-based display advertising and retargeting, which may include placing our advertisements on other websites you visit, including your social media accounts, or matching a cookie or device ID to your email address so we can send you promotional emails that may be of interest to you. We do not use, and do not enable third parties’ use of, cookies and other tracking technologies to collect information to help target content to you on the Website or elsewhere.
e. How to Control Cookies
You may disable or delete browser cookies through your browser settings. Cookies are generally easy to disable or delete, but the method varies between browsers. To learn how you can manage Flash cookies, visit Adobe’s Flash player settings page (opens in a new window). If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our websites may not work properly.
We note that some web browsers may be configured to send “Do Not Track” signals to online services you visit. We do not currently respond to “Do Not Track” or similar signals. However, you can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States or Canada by visiting the National Advertising Initiative’s (NAI) opt-out page (opens in a new window) and the Digital Advertising Alliance’s (DAA) opt-out page and in the European Economic Area (EEA) by visiting the Programme’s opt-out page (opens in a new window). You may also adjust advertisement and privacy preferences through your social media accounts. You may also opt out of certain Google Analytics activity by installing a Google browser extension, available here.
8. How You Can Manage Your Personal Information
You may manage your Personal Information by making certain choices. If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information if it is within your online account by logging in at any time or Contact Us using one of the designated methods in Section 13 below. You may also have additional rights detailed below depending on where you live. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.
If you no longer wish to receive direct marketing emails from TRAILS, you may click the “Unsubscribe” link in an email at any time to stop receiving emails for that particular subject.
9. Minors and Our Commitment to Children’s Privacy
We do not knowingly collect any Personal Information from anyone under the age of 13 or knowingly track the use of our Website by minors. Additionally, no part of the Website is directed to persons under the age of 13. If we becomes aware of having collected or maintained Personal Information about anyone under the age of 13, we will promptly delete the information unless your legal guardian or an educational organization authorized to act in place of your legal guardian has consented to your use of the Services
10. European Economic Area (EEA) and United Kingdom Residents
This Website is controlled and operated in the United States. If you choose to access the Website from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the programs and services available through the Website.
We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:
- Consent. We may obtain your consent to process your Personal Information in certain circumstances, which may include when you elect to receive information from us; you contact us to register an interest in our organization and/or the Services, including to receive materials regarding the same; or you participate in the Services.
- Performance of a Contract. We rely on this lawful processing ground when we process your Personal Information to perform a contract that we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection within the provision of the Services to you and the management of our relationships with third parties.
- Compliance with a Legal Obligation. We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.
- Legitimate Interests. We rely on this lawful processing ground when we process your Personal Information to provide the Services, to respond to specific requests, to manage our operations, to manage our relationships with you and with third parties in connection with our operations, and when we provide you with information in relation to our organization, the Services, or other offerings that we believe may interest you.
If you live in the EEA or United Kingdom, you may have the right to (1) request access to, rectification, or erasure of your Personal Information or restrict the processing of your Personal Information; (2) object to processing; (3) data portability (receive and transfer your Personal Information); (4) lodge a complaint with a supervisory authority; and (5) where processing of your Personal Information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of Personal Information that occurred before you withdraw consent.
For more information about our privacy practices, including to exercise an applicable right, please Contact Us using one of the designated methods in Section 13 below.
11. Third-Party Websites
For your information and convenience, this Website may contain links to third-party sites or services (e.g., a “share” function for social media platforms). We do not own, operate or control these websites or services, nor content or links that appear on such third-party websites, and we are not responsible for the practices employed by websites linked to or from the Website. Browsing and interaction on any other website, including websites that have a link to or from our Website, is subject to that website’s own terms and policies.
12. Changes to the Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in our privacy practices. We will post changes on this page and identify the date the privacy notice was last revised at the top of the page. We encourage you to frequently check this page to stay up-to-date on any changes. You acknowledge and agree that it is your responsibility to review this Privacy Notice periodically and become aware of any modifications since your last visit. Your continued use of the Website following the posting of changes to this Privacy Notice will be deemed your acceptance of those changes. If we make material changes to our privacy practices, we will notify you through a notice on the home page of the Website. If a material change will apply to Personal Information we have already collected, including any new purposes for which the Personal Information will be used or disclosed to which you have not previously consented, we will additionally seek your affirmative consent.
13. Contact Us
If you have questions about this Privacy Notice or want to exercise an applicable privacy right, please email us at privacy@trailstowellness.org. You may also write to:
TRAILS
535 W. William St. Suite #302
Ann Arbor, MI 48103
Attn: Privacy