The COMMIT Foundation, a Montana non-profit corporation (“COMMIT,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”) or their devices. By using or accessing our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Use.

Information We Collect

We collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide our Services or if we are legally required to collect it.

A. Information You Provide to Us

Participant Information. If you create an account or register to participate in our Pursue Your Purpose (“PYP”) Online Program, mentoring workshops, or transition assistance program, we ask you for your name, nickname, date of birth, email address, phone number, referral information, marital status, areas of interest for relocation, ethnicity, gender, LinkedIn profile, profile image, address, military occupation, military information, including last duty position, last rank, status, separation date, years of service, and branch, interests and motivations, goals, industries of interest, professional skills and experience, all responses provided within all PYP modules, and any other information we collect. When you provide responses as a participant in our programs, we evaluate the responses you provide to help evaluate your interests and better identify appropriate opportunities for you.

Payment Information. If you choose to donate to support our cause, a third-party service provider that handles payments for us will receive your payment card information.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact us for customer support, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

B. Information We Collect When You Use Our Services

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (“IP”) address, web browser type, operating system version, and mobile advertising identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, when you use our Services, we automatically receive information about your interactions with our Services, like the pages or other content you view, pages and videos you request, videos that you recently watched, your playlist, in some cases the websites you visited before using our Services, and the dates, times and durations of your visits.

Location Information. When you use our Services, we infer the general physical location of your device and the geographic regions our Users come from. For example, your IP address may indicate your general geographic region.

Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

C. Information We Receive from Third Parties

Third-Party Services. You may post photos or comments on our pages available through third-party platforms, including Facebook, Twitter, LinkedIn, Vimeo, and Instagram. If you do so, we and others may be able to view the information you make available through these third-party platforms.

Other Third Parties. We may receive additional information about you from third parties such as data or marketing partners and combine it with other information we have about you.

How We Use the Information We Collect

We use the information we collect when you use our Services:

• To provide, maintain, improve, and enhance our Services;
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To process reports about responses from conduct sentiment analysis for participants in our programs
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
• To facilitate transactions and payments;
• To de-identify and aggregate information collected through our Services and use it for any lawful purpose;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

If you are located in the European Economic Area, we only process your information based on a valid legal ground, including when:

• You have consented to the use of your information;
• We need your information to provide you with our Services, including to respond to your inquiries;
• We have a legal obligation to use your information;

We or a third party, have a legitimate interest in using your information. We only rely on our or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

How We Share the Information We Collect

We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of collection.

Partners and Affiliates. We may share any information we receive with our partners and affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with contractors, vendors, service providers, and other third parties retained in connection with the provision of our Services.

Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout

Required by Law and Similar Disclosures. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose or transfer information about you to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

At Your Direction. We may disclose information about you to fulfill the purpose for which you provide it.

Consent. We may also disclose information from or about you or your devices with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

If you are located in the European Economic Area, you have these following additional rights in relation to your information that we hold:

• Where we rely on consent for the processing of your information, you have the right to withdraw your consent at any time.
• You have the right to access the information we hold about you, and to receive an explanation of how we use it and who we share it with.
• You have the right to correct any information we hold about you that is inaccurate or incomplete.
• You have the right to request for your information to be erased or deleted.
• You have the right to object to our processing of your information where we are relying on a legitimate interest.
• You have a right in certain circumstances to stop us from processing your information other than for storage purposes.
• You have the right to receive, in a structured, commonly used and machine-readable format, information that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such information to a third party.
• You have the right to lodge a complaint with a data protection supervisory authority in the country in your country of residence, place of work or where an incident took place.

We may require you to provide certain verification information so that we know that you are you. This may include verifying information that you provided via our Services. Upon receiving such a request, we will act as promptly as possible to respond to your request as provided above and in no event later than applicable law requires.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use information from or about you, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect information from or about you by using technical and organizational safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, please alert us at info@commitfoundation.org.

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring information from or about you or your devices outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including information from or about you or your devices, on or to our Services, you consent to such transfer, storage, and processing.

When we transfer information outside of the European Economic Area we will comply with applicable EEA data protection laws. We may transfer your information to countries which have been found to provide adequate protection by the European Commission (e.g. Switzerland and Canada), we may use contractual protections for the transfer of information, or rely on a legal derogation. You may contact us as specified below to obtain a copy of the safeguards we use to transfer information outside of the European Economic Area.

Update Information

You can update your registration and account information by contacting us at info@commitfoundation.org.

Changes to This Privacy Policy

This Privacy Policy may be revised from time to time. We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective as of the last updated date below. If we materially change the ways in which we use or share information from or about you or your devices previously collected from you through our Services, we will make reasonable efforts to notify you through our Services, by email, or other communication.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at info@commitfoundation.org or write to us at 280 West Kagy Blvd., Suite D 313, Bozeman, Montana 59715.

Last Updated: 08/25/2020

Privacy Policy