Summary of Important Points in this Policy

• Personal Information. We may collect and process personal information when you visit, use, or navigate our Services. This depends on how you interact with us, the choices you make, and the features you use. Learn more.
• Sensitive Information. We may process sensitive personal information, but only with your consent or as permitted by law.
• Information Processing. Your information is processed to provide, improve, and manage our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations. We only process your information when we have a valid legal basis.
• Information Sharing. We may share your personal information in specific situations with specific categories of third parties, such as service providers, business partners, and legal authorities.
• Information Security. We implement organizational and technical measures to protect your personal information. However, no method of electronic transmission or storage is completely secure, so we cannot guarantee absolute security.
• Your Rights. Depending on your location, you may have certain rights regarding your personal information, such as accessing, correcting, or deleting your data.
• Exercising Your Rights. You can exercise your rights by emailing us at info@bellwethersgroup.org. We will review and respond to your request in accordance with applicable data protection laws.

For more information, please read the entire Policy below.

Personal Information We Collect About You

“Personal information” refers to data that pertains to you or other individuals from which you or they can be identified

We collect several types of personal information from and about users of our website, including information about:

• How to contact you, such as name, postal address, e-mail address, and telephone number
• Your workplace, such as your company’s name, position title, organizational affiliations and related information
• Your internet connection, the equipment you use to access our Website and usage details – see further in the “Automatic Data Collection Technologies” section below

Intended Audience

The Website is intended for individuals that are over the age of 16. MINORS ARE EXPLICITLY PROHIBITED FROM SUBMITTING THEIR PERSONAL INFORMATION (AS DEFINED BELOW) OR OTHERWISE ENGAGING WITH THE WEBSITE. If we learn that we have any information from anyone who is under the age of 16, we will delete that information.

How We Collect Your Personal Information

We collect your personal information directly from you when you provide it to us. This will include personal information you provide:

• When interacting with various tools on our Website, including filling out information fields, signing up and interacting with our newsletters, requesting further information, among others
• When you report a problem with our Website or contact us for any other purpose
• When you provide information to be published or displayed on the Website, or to be transmitted to other users of the Website or third parties.

We also collect your personal information through our use of automatic data collection technologies – see further in the “Automatic Data Collection Technologies” section below.

We may also collect or receive personal information about you from various third parties and public sources, including but not limited to:

• Technical Data from the following parties: analytics providers, such as Google and search information providers, and CRM (Customer Relationship Management) platforms

Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information from and about your equipment, browsing actions, and patterns, including:

• Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website
• Information about your computer and internet connection, including your IP address, operating system, and browser type

“Do Not Track” – Certain laws, including that of California, require that we inform you on our response to Do Not Track signals. As there is not an industry or legal standard for recognizing or honoring these signals at this time, we don’t respond to them.

The information we collect automatically is statistical data we may use to improve our website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns
• Store information about preferences, allowing us to customize our Website according to individual interests
• Speed up searches
• Recognize you when you return to our Website

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the “Choices About How We Use and Disclose Your Personal Information” section below.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Personal Information

We have set out below the purposes for which we use your personal information. We are required under EU and UK data protection law to identify a legal basis for using your personal information – we have highlighted these below:

• To present our Website and its contents to you (to achieve our legitimate interest in making this content available to you in an effective way)
• To provide you with information, or services that you request from us (with your consent)
• To notify you about changes to our Website or any services we offer or provide through it (to achieve our legitimate interest in ensuring we provide our services to you effectively)
• To allow you to participate in interactive features on our Website (to achieve our legitimate interest in ensuring we provide our services to you effectively)
• To contact you about events, convenings and information that may be of interest to you (with your consent)
• To log you in into the Members page and to authenticate your login
• To develop and maintain your profile on the Members’ page
• To connect you with other members of your specific Bellwethers’ closed network(s)
• To facilitate other members of your specific Bellwethers’ closed network(s), find and access your profile
• To provide your name, company’s name, position title, organizational affiliations and related information to other members of your specific Bellwethers’ closed network (s). You should be aware that the personal information you post in your Member page is available to access by anyone of your Bellwether’s closed network(s)
• To generate reports
• In the manner set out in the “Disclosure of Your Personal Information” section below.

If you do not provide us with the personal information required to perform our services with you or comply with our legal or statutory obligations (highlighted as such in the list above), we may not be able to provide those relevant services to you. If you consent to our use of your personal information and this consent forms the legal basis of our processing of that personal information, you are entitled to withdraw it at any time – see the “Your Rights With Respect To Your Personal Information” section below for more detail.

Disclosure of Your Personal Information

We may disclose personal information that we collect or that you provide as described in this Policy:

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations, to keep personal information confidential and use it only for the purposes for which we disclose it to them and in accordance with our instructions.
  Our current service providers and third-party vendors include:
  • Cloud services
  • CRM platforms
  • Analytics platforms
  • Social media platforms
    This list is subject to change at any time and without notice.
• To maintain Bellwethers closed networks interactions
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bellwethers, our customers, or others.
• For any other lawful business purpose such as improving products, services, marketing, and user experience.

Choices About How We Use and Disclose Your Personal Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Your Rights With Respect To Your Personal Information

If our processing of your personal information is subject to EU and UK data protection law, you have a number of rights. These include, in certain circumstances:

• To object to the processing of your personal information. To make such a request, please contact us at the email address provided below. We will consider and act upon any request in accordance with applicable data protection laws.
• To receive a copy of all your personal information held by us, in order to check we are processing it lawfully
• To ask us to correct any errors in your personal information
• To ask us to delete your personal information, including when exercising your right to object to processing (see above), unless we have a compelling reason to continue with such processing
• To ask us to restrict the processing of your personal information in certain situations (such as where there is an outstanding question you have raised regarding its accuracy)
• To ask us to transfer your personal information to another party, where we have collected it from you to perform a contract or are processing it on the basis of your consent
• To withdraw your consent where you have provided it for our collection or use of your personal information for a specific purpose, subject to certain conditions
• To unsubscribe from our emails at any time by clicking the “Unsubscribe” link found in the footer of every email that is sent to you (except for emails that were personally sent to you in response to an inquiry). Please note that we will never send you deceptive or misleading marketing messages. Your information is safe with us and unless necessary, we will not share your email address with anyone else. We will also never sell your information to any third-party
• To upload, modify or eliminate your personal information when setting your profile on the Member page
• To ask us to eliminate your Member page. We can retain the personal information of your Member’s page even after you have closed your account if reasonably necessary to comply with our legal obligations

You may exercise these rights at any time by contacting Bellwethers Group, a sponsored project of Rockefeller Philanthropy Advisors, using the details in the “Contact Information” section of this Policy.

We may not be able to accommodate a request relating to your personal information in certain circumstances prescribed by law. Please contact us using the details in the “Contact Information” section of this Policy if you would like more information.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes for which we use it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

For Members accounts and profiles, account information is retained as long as the account is active and the user has not requested its deletion, and nor has it been deleted. We may keep some of members’ personal information to the extent needed to be in compliance with our legal obligations, to resolve disputes and enforce any agreements we have with the users.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

EU located individuals: International Transfers

We share your personal information within Bellwethers Group, a sponsored project of Rockefeller Philanthropy Advisors, based in the United States of America. This involves transferring your personal information outside of the European Economic Area (“EEA”) and UK to countries whose laws are not deemed to provide a level of protection for personal information that is of the same standard as enjoyed under data protection law in the European Union and the UK.

We may also share your personal information with contractors, service providers and other third parties supporting our business when needed. Some of these third parties are based outside of the EEA and the UK, so their processing of your personal information will involve a transfer of data outside of the EEA and UK.

Whenever we transfer your personal information out of the EEA or UK, whether internally within our group or externally to other parties, we ensure proper protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission
• We may use specific standard contract clauses approved by the European Commission or UK Information Commissioner’s Office (also conducting any required transfer impact assessment and, if necessary, implementing supplementary measures) to make sure that the transferred personal information is given an appropriate level of protection in accordance with applicable data protection law when being processed outside the EEA or UK.

Alternatively, in certain circumstances we may transfer personal information outside the EEA or UK relying on specific derogations under applicable EU and UK data protection law, including where you (or the relevant individual) have provided your (or their) explicit, informed consent to the transfer; the transfer is necessary for the purposes of being able to enter into or perform a contract with you (or another individual) at your (or their) request; or, the transfer is needed in connection with a legal claim (or possible legal claim).

Please contact us if you want further information on the specific mechanisms used by us when transferring your personal information out of the EEA or UK.

Special Privacy Rights for California Residents.

California Civil Code Section §1798.83 (the California "Shine the Light" law) permits users of our Website that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. This request can be made once a year and will be provided free of charge.

Am I a California “resident”?

Under the California Code of Regulations a "resident" is defined as (1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

Pursuant to this Policy, in the last twelve (12) months, we may have collected personal information about you, as identified in this Policy. In the past twelve (12) months we also may have disclosed some of your personal information to third parties for business or commercial purposes. The third parties to whom we may have disclosed this personal information for business or commercial purposes can be found in the Section titled "(whichever section identifies third-party vendors, etc.)" California residents have the following specific rights with regard to their Personal Information:

• You can ask us to delete your Personal Information. If you make any such request, we will honor your request, subject to certain exceptions provided by law, including, but not limited to, the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
• Depending on the circumstances, you can request to know:
  • Whether we have collected and used your Personal Information;
  • The general categories of personal information that we collect;
  • How we use your collected Personal Information;
  • Whether we sell your Personal Information to third parties;
  • The general categories of personal information that we sold or disclosed for a business purpose;
  • The third parties to whom your Personal Information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting or selling personal information.
• You have the right not to be discriminated against if you exercise your privacy rights.
• You have the right to object to the processing of your personal information.
• You may request to correct your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the data.
• You can designate an authorized agent to make a request under the CCPA on your behalf.
• You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

Contacting Us

To exercise these rights, you can email us at info@bellwethersgroup.org. If you have a complaint about how we handle your data, we would like to hear from you.

For your added protection we may require that you email us from the email account we have on file and associated with you. In certain cases, we may request additional information to identify you.

We will only use personal information provided in your request to verify your identity or authority to make the request. We will avoid requesting additional information from you for the purposes of verification, if at all possible; however, if we cannot verify your identity from the information that we already have, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We may also need to verify your identity and address before we process your request. If this happens, we will ask you to provide a copy of your driver’s license, government-issued ID, passport, or recent utility bill. We will delete such additionally provided information as soon as we finish verifying you.

Please note, if you are using an authorized agent to make your request, we may deny any such request it your authorized agent does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

Data Security

We take the security of your information very seriously and we use all commercially reasonable means to protect this information. Although we will do our best to protect your personal information, you should only access the Website within a secure environment, and you agree that you access the Website at your own risk. We have implemented appropriate internal security measures to prevent your Personal Information from being inadvertently lost, accessed or misused. Your Personal Information is only shared on a “need-to-know” basis, and only with the trusted parties identified in this Privacy Policy.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, all information you provide to us is stored on our secure servers behind firewalls. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, no method of transmission over the internet or electronic storage method is completely secure and we cannot guarantee that your personal information will be kept absolutely secure from hackers, cybercriminals, or other unauthorized third parties who are able to defeat our security, and improperly collect, access, steal, or modify your information, especially when your information is transferred to, stored and processed by our third-party vendors. If such a data breach occurs, we have internal procedures in place to deal with any such breach and when we are legally required to do so, we will notify you of the same.

Changes to Our Policy

We may revise and update this Policy from time to time in our sole discretion. All changes are effective immediately when we post them, and apply to all access to and use of the Website and handling of your personal information thereafter. It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page.

In order to ensure that the permissions granted to us by you remain accurate and up-to-date, we will periodically review and refresh these permissions for accounts that have existed for an extended period of time. This process will involve prompting you to review and confirm your consent to the continued use of your personal information for the purposes outlined in this Privacy Policy.

Contact Information

To ask questions or comment about this Policy and our privacy practices or if you are based in Europe or the UK and wish to exercise your rights under data protection law as described above, please contact us at info@bellwethersgroup.org.

Before we can respond, we may need to ask you to verify your identity and/or clarify the nature and scope of your request.

Complaints

If you are concerned about how we use your personal information and we are unable to resolve your issue, you have the right to make a complaint to the supervisory authority in your place of work or residence or the place in which the relevant infringement has taken place.