Privacy Notice
Last Updated: October 1, 2024
Introduction
We at Transforming Research into Action to Improve the Lives of Students, a Michigan-based 501(c)(3) charitable organization, (“TRAILS”, “we”, “us”, “our”) respect you (“you”, “your”) and your privacy and are committed to protecting the Personal Information (defined below) you provide to us. This Privacy Notice (“Privacy Notice”) describes the types of Personal Information we collect, and how we use, maintain, protect, and disclose it, when you interact with our website (at https://trailstowellness.org/), corresponding platforms (collectively, “Platform”), related services, and content. Related Services include, without limitation, modules and pathways, reports, questionnaires and surveys, speaking engagements, conferences, trainings, and other program offerings; and any other situations when you choose to share your Personal Information with us (collectively, “Services”). Through the TRAILS Platform and Services, we provide access to various content, including, without limitation, software, technology, and related materials (collectively, “Content”). The Privacy Notice also describes the rights and choices you may have with respect to your Personal Information and how you may contact us about our privacy practices.
TRAILS believes in transparent, respectful, lawful use of Personal Information. We do not buy or sell individuals’ Personal Information, nor do we share Personal Information with third parties for the purposes of targeted advertising. 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 parties to collect, non-anonymized information about individuals without their knowledge and consent.
By signing up for a TRAILS account, whether for free or through a subscription, or otherwise by accessing or using our Platform, Services, or Content, you acknowledge that you have read, understood, and agree to be legally bound by, without modification, all terms and conditions of the Privacy Notice and Terms of Use (at https://trailstowellness.org/terms-of-use) (collectively, “Agreement”), and any applicable laws and regulations. If you do not agree to the Agreement, you must refrain from signing up for an account, or otherwise accessing or using the Platform, Services, or Content.
If you are signing up for a TRAILS account, or otherwise accessing or using the Platform, Services, or Content on behalf of an organization, you represent, warrant, and confirm that you have the authority to bind the organization or legal entity to the Agreement, and any applicable laws and regulations, and acknowledge and agree that “you” and “your” will refer and apply to you and the organization or other legal entity on whose behalf you are acting.
In order to access and use the Platform, Services or Content, you will have to create an account, either for free or through a subscription, by providing information such as your name, email address, and password (collectively, “Account Information”). By signing-in using your Account Information, you are authorizing us to collect, store, and use, in accordance with this Privacy Notice and Terms of Use, any and all Account Information. We use Account Information to process the creation of your account, including, among other things, to verify your identity, and to manage your account, including your transactions.
This Privacy Notice is not a contract and does not create any contractual rights or obligations.
In the event of any conflict between Agreement and a separately executed written contract between TRAILS and you or your affiliated organization, the terms of the signed written contract shall control and supersede with respect to the subject matter in conflict, without otherwise limiting the applicability of remaining provisions.
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.
In the course of operating the Platform or Services, providing Content, and/or interacting with you, we may collect and/or receive the following types of Personal Information, which you authorize us to collect and/or receive:
Contact information (including name, mailing address, email address, phone number, school/district)
Account information (including name, email address, username, date of birth, gender, log-in credentials)
Demographics (including gender, language preference, sexual orientation, educational history, race, ethnicity, employment information, household information, national origin)
User engagement information (including platform analytics such as login frequency, return usage, access of Services or Content, searches within Platform, content engagement, organization affiliation, responses to modules, and feedback)
Business and employment information (including business contact information, department, job title / description / role)
Social media information (including username, biography, and other information that you chose to publicly share on social media networks)
Technical details (including 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
Other Information You Provide (any information that you choose to share with us when interacting with the Platform, Services, or Content)
We will not collect student-level data for students under the age of 18. You should not enter, upload, or share any identifying information about students in the Platform or within Services for students under the age of 18.
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, operating, administering, and maintaining the Platform, Services, or Content
Authenticating use, detecting potential fraudulent use, or otherwise maintaining the security of the Platform, Services, or Content
Monitoring, developing, testing, tailoring, and improving the Platform, Services, or Content including its performance and functionality
Implementing TRAILS programming including analyzing progress of modules or pathways, engagement patterns, and resources being accessed or used
Creating and maintaining a customer relationship management system
Complying with legal and contractual obligations, internal policies, practices, and processes, 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 assurances, evaluations, reporting, publications, presentation, research collaborations, or communications about TRAILS program
Administering, registering, 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 or Content
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 in, funding, administering, and/or auditing the Services or Content, as well as their employees and agents
To background check providers and/or consumer credit reporting agencies
To third-party service providers (which may include donations processor(s), fraud screening providers, analytics providers, hosting providers, and other third-party service providers) to help us operate the Platform or Services and administer certain functions, services, or activities on our behalf
When you use a third-party feature in our Platform or via Services, or Content. This may include social media networks when you share content through those networks or use a social media account to log in to our Platform
To third parties with whom you choose to share content regarding the Services
To enforce or apply our Terms of Use, Privacy Notice and other agreements or comply with any court order, law, or legal process, including government or regulatory requests
To advisors, consultants, auditors, affiliates, 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.
We take reasonable measures to seek to require third parties receiving Personal Information from us to: (a) retain and use such information for the specific business purpose(s) for which the Personal Information has been provided to them; (b) not disclose Personal Information except with our authorization, as permitted by applicable law, or as permitted by this Privacy Notice; and (c) use reasonable measures to safeguard the Personal Information.
5. How We Protect Personal Information
We implement security safeguards to protect your Personal Information. We take steps to secure Personal Information through commercially reasonable administrative, technical, organizational, and physical measures designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, no security system is impenetrable, nor can we guarantee the security of information transmitted through the Internet. 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 in this Privacy Notice and the Terms of Use; for as long as your account is active (e.g., for your subscription period); as needed to provide, administer, maintain, operate, and support the Platform, Services or Content; or 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 us or by third parties when you access or use the Platform, Services, or Content. 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 Platform. They are commonly required for the Platform 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 Platform for the following purposes:
Essential: Some cookies are strictly necessary, and we use them in order for the Platform to function, for example to ensure you can move around and use our Platform effectively. They are only set in response to your actions when you use Services or Content, such as cookies that enable you to log into secure areas of the Platform.
Performance/Functionality: Cookies, web beacons, and IP address logs allow us to measure and improve the performance of our Platform. For example, we may collect information in the aggregate to give us insight into how the Platform, Services, or Content is being used, such as what websites you came from, what pages of the Platform you visit, how long you were on the Platform, 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 Platform, 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 Platform.
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 Platform 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 macromedia.com. 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 Platform 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) and the Digital Advertising Alliance’s (DAA) opt-out page and in the European Economic Area (EEA) by visiting the Programme’s page. 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 within your online account by logging in at any time or by contacting us using one of the designated methods in Section 13. Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. To make a request on your behalf, an authorized agent may contact us by email with proof of your written and signed permission to do so. Note that we may also require you to verify your identity and confirm that you have given permission.
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 18 or knowingly track the access to or use of our Platform by minors. Additionally, no part of the Platform is directed at persons under the age of 18. If you are under 18, do not use or provide any information on the Platform. If we become aware of having collected or maintained Personal Information about anyone under the age of 18, we will promptly delete the information. If you believe we might have any information from or about a child under 18, please Contact Us using one of the methods specified in Section 13.
10. Third-Party Websites
The Platform, Services, and Content may contain links to third-party websites not owned or controlled by TRAILS (“External Sites”). TRAILS is not responsible for the content or practices of any External Sites and does not make any representations regarding the content or accuracy of materials on such External Sites. You should contact the website administrator or webmaster for those External Sites if you have any concerns regarding such links or any content located on such External Sites. Your use of External Sites is entirely at your own risk and subject to External Sites own terms and policies. You assume all responsibility for such interactions.
11. Jurisdiction Specific Notice
This Platform is controlled and operated in the United States. If you choose to access the Platform 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 Services or Content available through the Platform.
Additional Notice to Certain Other U.S. Residents
If you are a resident of certain U.S. States, you may have some or all of the following rights. These rights are based on verifiable residency status, and we reserve the right to honor your request to exercise these rights based on your residency and application of state law. You may have the right to request the following: (i) that we disclose and provide a copy of what Personal Information we collect, use, share, or disclose; (ii) that we delete your Personal Information, subject to certain exceptions; (iii) that we correct inaccurate or incomplete Personal Information; (iv) that we limit use or disclosure of certain information; (v) opt-out of the sharing of Personal Information; and (vi) not receive discriminatory treatment by us for exercising these rights.
To make such a request, please contact using one of the methods specified in Section 13. If you are appealing our decision, please attach information to identify your original request. In order to verify your request, we may require you to provide additional information to confirm your identity.
Additional Notice to European Economic Area (EEA) and United Kingdom Residents
Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a Service you have with us but will notify you first.
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 Content 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.
Additional Notice to Canada Residents
We may use service providers located outside of Canada, including, without limitation, in the United States of America, to process Personal Information, and may transfer your Personal Information to such service providers for this purpose. When your Personal Information is processed outside of Canada, it will be subject to the laws of the countries where the information is processed and may be accessible to law enforcement and national security authorities of those countries in accordance with their laws.
You may Contact Us to obtain information about our policies and practices regarding the use of service providers located outside of Canada.
If you live in Canada, in addition to the other rights you may have hereunder, you may have the right to: (i) request access to, review and to correct inaccuracies or omissions in your Personal Information; (ii) to withdraw consent for collection, use or disclosure of, or to request deletion of, your Personal Information (provided that, if you do so, we may no longer be able to provide services to you that rely on such Personal Information); (iii) to ask questions about our policies and practices, and to lodge complaints about our compliance with them with us or with regulatory authorities; and (iv) for Quebec residents, to request an electronic copy of the Personal Information you have provided to us in a structured and commonly used technological format.
To make such a request, please follow contact us using one of the methods specified in Section 13 below.
12. Changes to the Privacy Notice
We may update the Privacy Notice from time to time to reflect changes in our privacy practice. We will post changes on this page and identify the date the privacy notice was last revised. 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 and become aware of any modifications since your last visit. If a material change is made, for example, a new purpose for which Personal Information will be used or disclosed, you will be informed about such change when logging in to your account. Your continued access to or use of the Platform, Services, or Content following the posting of changes to the Privacy Notice will be deemed your acknowledgment of those changes and acceptance to the Agreement.
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
4750 Venture Drive, Suite 400-PMB 1010
Ann Arbor MI, 48108
Attn: Privacy