Privacy Policy

Communio Foundation, a noncommercial, public benefit, religious  nonprofit corporation incorporated in District of Columbia, United States, and is described as a public charity under sections 501(c)(3) of the United States Internal Revenue Code (“Communio Foundation,” “we,” “us,” or “our”), Communio Foundation respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how Communio Foundation handles your personal information after receiving it.  This Privacy Policy governs Communio Foundation’s use of your information on the Communio Foundation website (https://communio.org), any Communio-conducted survey through http://communioinsights.org, and includes your use of the materials, programs and Communio Foundation brand (collectively, “Website”).

Please read this Online Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

  1. Children Under the Age of 18

Our Website is not intended for children under 18 years of age without parent consent and supervision.  The subject matter and materials of the Services are intended for churches doctrinally defined as trinitarian, their staff and authorized volunteers, and mature couples and individuals seeking to address significant spiritual and relational issues.  No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18 do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent and supervision, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at set forth in paragraph 16 herein.

  1. CCPA Information and Disclosures

Under the California Consumer Privacy Act of 2018 (“CCPA”) California residents may have additional rights regarding the collection and sale of their personal information.  Please see California Privacy Rights Notice at https://oag.ca.gov/privacy/ccpa for more information.

For purpose of compliance under CCPA, please know that we collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“CCPA Personal Information”). CCPA Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

In particular, we have collected the following categories of CCPA Personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to us by your personal information.

  1. The Services

Through its Website, Communio Foundation supports churches in effectively impacting their communities by provides online teaching, training, classes, mentoring, courses, forums, programs, marketing materials, analytics, interactive studies, videoconferencing, webinars, and other educational materials and services (collectively the “Services”).

  1. Types of Information Collected and Stored

    Personal Information Summary

When you engage in activities such to use Communio Foundation’s services on our website, such as create a website user profile on our website, create an account, sign up to receive a publication, register to become a member, register for a class, course, or other educational materials, register for credentials or certification, register for a test, register for a conference or other event hosted by Communio Foundation, shop on our website, or otherwise use our website, Communio Foundation may gather your personally identifiable information (collectively “Personal Information”).

Your Personal Information may include, but is not limited to, your name, address, phone number, images, photograph, video and/or other graphic representations, your voice data, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Communio Foundation or its authorized agents.

By using the Website and the Services, you agree to allow Communio Foundation and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

  • Specific types of data we collect about you. For the purpose of providing the Services and our legitimate business purposes, We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
    • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data. When you use Communio Foundation website to shop for or to purchase Communio Foundation seminars, programs, courses, or other educational materials, register for Communio Foundation analytics or reports, or purchase other materials, Communio Foundation utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Communio Foundation concerning your payment.  Communio Foundation and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information.  Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant.  As a result, Communio Foundation does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary.  For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.
    • Transaction Data includes details about payments to and from you and other details of Communio Foundation products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your Communio Foundation login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    • Profile Data includes your Communio Foundation username and password, Communio Foundation purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use the Communio Foundation website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    • Aggregated Data / Analytics Information. We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Communio Foundation website, Communio Foundation gathers this Aggregated Data related to individuals’ website visits.  This information is used solely to measure and improve our website and services and to better serve our members and customers.  Communio Foundation uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:
      • Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.
      • Non-personal information, such as language, zip code, area code, location, and the time zone.
      • Communio Foundation website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Communio Foundation website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.

Sensitive Information

We do not collect the following Special Categories of personal data about you.  Such Special Categories include details about your race or ethnicity, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We may collect Special Categories of personal data about you religious and/or philosophical beliefs.

Through your participation in the Services, you may, but need not, freely and voluntarily choose to post, share, provide contributions, or otherwise disclose Personal Information described within such Special Categories.  Your sharing of Special Categories of personal data will not be requisite for your participation in the Services and We cannot guarantee the privacy of such disclosures described in this Section.

Cookies and Browser “Do Not Track” Notice

  • Communio Foundation may use cookies on your computer. A cookie is a small text file sent from a website and stored in a user’s web browser while the user is browsing that website.  Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity.  Communio Foundation does not, at present, permit third party advertisers on its Website.  In the event that Communio Foundation chooses to permit third party advertisers, such third parties will not have access to Communio Foundation cookies, but they may use their own cookies on your computer.  Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies.  Communio Foundation does not correlate its use of cookies with your Personal Information.
  • Communio Foundation does not respond to browser Do Not Track (“DNT”) Signals. Communio Foundation websites may utilize page tags or web beacons to track information related to user visits as a part of Communio Foundation data analytics processes and user experience customization as described below.  Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website.  Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website.  Such technologies enable us to improve and customize user experiences while users visit our website.  Communio Foundation does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.
  • Communio Foundation may employ third party data analytics firms to track and analyze traffic on the Communio Foundation website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking. These services also use cookies to accomplish such analytics-related services.  Communio Foundation’ third party analytics firms, process the Personal Information they receive through the use of cookies in the aggregate.
  • Third parties that may advertise on Communio Foundation websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Communio Foundation website. Such information may contain a visitor’s IP address.  Third parties may not collect identifying Personal Information from the Communio Foundation website unless you provide it to such third parties.
  • You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Keeping Information Updated

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

  1. Security of Personal Information

Communio Foundation takes the security of your Personal Information very seriously.  When your Personal Information is stored by Communio Foundation, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure.  While Communio Foundation will use all reasonable means to protect your Personal Information, Communio Foundation cannot guarantee the security of your transmissions of such Personal Information, and you use the Communio Foundation website at your own risk.  If you suspect your Personal Information has been compromised, please notify Communio Foundation Customer Service using the contact information provided below.

  1. How we Collect Your Personal Information

    We use different methods to collect data from and about you including through the following methods.

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • Enter into an agreement with Us to provide the Services.
      • apply for our Services;
      • create an account on our Website;
      • subscribe to our Services or
      • receive our publications;
      • request marketing to be sent to you;
      • enter a competition, promotion or survey; or
      • give us feedback or contact us.
    • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
    • Technical Data from the following parties:
      • analytics providers such as Google based outside the EU;
      • advertising networks based inside OR outside the EU; and
      • search information providers based inside OR outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
    • Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.
    • Identity and Contact Data from publicly available sources.
  2. How Communio Foundation Uses and Shares Your Information
    • General Information and Your Rights. Communio Foundation limits its use of your Personal Information to the stated purposes for which such information is collected.  In some cases, Communio Foundation may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  You have the right to the following regarding your Personal Information transferred to Communio Foundation:
      • To know the types of Personal Information Communio Foundation collects;
      • To know the purposes for which it collects and uses your Personal Information;
      • To know type or identity of third parties to which Communio Foundation discloses your Personal Information, and the purposes for which it does so;
      • To access and update your Personal Information; and
      • To know the choices and means Communio Foundation offers you for limiting the use and disclosure of your Personal Information.
    • Communio Partner Churches.

We may provide your Personal Information to churches with whom we have contractual agreements to provide marketing and outreach services tailored to the churches’ specific ministry needs to you.

Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.

  • Communio Foundation Services to Communio Foundation Account Holders

When you create an Communio Foundation account, we may use information collected from technologies such as cookies, web beacons, and page tags, as described herein, to improve your experience of our website.  For example, by saving information concerning the pages you visit and products you purchase, we will be able to provide you with information on other Communio Foundation goods and services that may be of interest to you. Furthermore, by creating an account with Communio Foundation, there is a possibility of receiving content from third parties through Communio Foundation, as discussed under Section 6.6, below.

Based on the information we gather, we may use targeted advertising from third party vendors, customized to reflect your interests.  For example, if you purchase certain materials from Communio Foundation, Communio Foundation may display advertisements from vendors of similar materials.  To accomplish this, we may use cookies and other technologies in order to recognize your computer at the time we display an advertisement to you.  Communio Foundation may tailor advertisements based on your use of our website, such as tracking the pages you visit, the searches you make, or the goods or services you purchase.   Communio Foundation may correlate activities described in this section with your Personal Information, but we will not provide advertisers with your Personal Information when you view a targeted advertisement.  However, through your interaction with a targeted advertisement, you consent that an advertiser may infer that you meet certain targeting criteria for the display of the advertisement.

In creating an Communio Foundation Account, and as a condition of having an Communio Foundation Account and utilizing the Services, you must expressly consent to Communio Foundation’ collection and use of your Personal Information and non-personally identifiable information as described in this Online Privacy Policy.  Moreover, in using a Communio Foundation Account and the Services you expressly acknowledge and agree to our collection and use of such information as described in this Online Privacy Policy.

You can opt-out of the use of your Personal Information as described in this Online Privacy Policy by deleting your Communio Foundation Account.  To delete your Communio Foundation Account, please contact Communio Foundation Customer Service using the contact information provided below.

  • Other Communio Foundation Services

Communio Foundation may use your Personal Information to provide services to you upon your request.  Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Communio Foundation website, emailing you updates concerning Communio Foundation products and services, and personalizing your visits to Communio Foundation website.

You may opt-out of the use of your Personal Information as described in this Section by contacting Communio Foundation Customer Service using the contact information provided below.

  • Communio Foundation Internal Data Sharing

Communio Foundation may also share your Personal Information with other Communio Foundation offices or Communio Foundation affiliates       in the country in which you reside and in other countries.

  • Information Sharing with Third Parties
    • Except as set forth in this section 6, Communio Foundation will not share or swap your Personal Information, or any church membership information, with any third parties. As more fully described below, Communio Foundation’s data sharing will be limited to such sharing as is required for Communio Foundation to provide its services to you.
    • This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
    • Communio Foundation may utilize third-party service providers and data processors that process your Personal Information solely on Communio Foundation’ behalf (“Agents”). When Communio Foundation transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes.  Communio Foundation will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the Principles.  Communio Foundation remains responsible and liable if the Agents that Communio Foundation engages to process your Personal Information on Communio Foundation’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Communio Foundation proves that it is not responsible for the event giving rise to the damage.
    • Communio Foundation uses consultants and third party vendors and may share your Personal Information with such consultants and vendors, if necessary, for delivery or administration of the Communio Foundation Services. All parties with which Communio Foundation shares your personal information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.  Communio Foundation’ agreements with third parties provide that third parties will delete your personal information upon request.
    • Communio Foundation may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.
    • Communio Foundation uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services. All parties with which Communio Foundation shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.
    • Communio Foundation may partner with third parties to provide other specific services, including, but not limited to registration for Communio Foundation courses, classes, webinars, retreats, conventions, meetings, physical gatherings and events, and other Communio Foundation educational materials and Services. When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services.  Communio Foundation may auto-populate forms utilized by these third parties with data contained in Communio Foundation managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services.  All parties with which Communio Foundation shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.
  • Other Possible Disclosures

In addition to the other disclosures stated herein, Communio Foundation may share your information in the following ways:

  • To comply with applicable laws, regulations, legal processes, or government enforced orders,
  • To enforce applicable terms of service, protect our legal rights or defend against legal claims,
  • To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,
  • To comply with Communio Foundation’ obligations to address complaints arising under its obligations, including disclosure to EU Data Protection Authorities, or other necessary entities.
  • To guard against harm (whether actual or potential) to the legal rights, property or safety of Communio Foundation, our visitors or the general public as required or permitted by law.
  1. International Transfers
    • We share your personal data within Communio Foundation. This will involve transferring your data outside the European Economic Area (EEA).
    • Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
  2. Communio Foundation Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer, student or member. (a) Identity

(b) Contact

(c) Financial

Performance of a contract with you
To register you for Communio Foundation classes, courses, webinars, events, conferences and programs. (a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e)  Financial

(f)  Transactional

a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To conduct the classes, courses, keeping record of attendees, webinars, forums, mentoring, educational programs and otherwise provide the Services. (a) Identity

(b) Contact

(c) Profile

(d) Audio-Visual

(e) User Contributions

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to enable your full participation, and to enable full functionality of the website, provide educational content, and to enable full functionality of the Services).

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(c)  Managing Communio Foundation member services.

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(e)  Financial

(f)  Transactional

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) User Contributions

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and improve our services to our users)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) User Contributions

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and to inform our marketing strategy)
To develop new marketing materials and advertising. (a) Audio-Visual

(b) User Contributions

Necessary for our legitimate interests to grow and develop and grow our educational services.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

(c) Audio-Visual

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products and educational services)

 

  1. Data retention
    • We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data 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.
    • To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
  2. Communio Foundation Email Uses
    • Communio Foundation never rents or sells email addresses to outside parties without your consent. Occasionally, you may wish to receive information or communication from a Communio Foundation participant.  In that instance, you will be asked for permission to share your email address.
    • After you create an online account with Communio Foundation, you will receive information about Communio Foundation products, services, and educational offerings that relate to your areas of interest unless you choose to opt-out. If you have questions or concerns about Communio Foundation’ Online Privacy Policy or wish to no longer receive such offers (opt-out), please contact Communio Foundation Customer Service using the contact information provided below.
  3. How to Access or Change Your Personal Information
    • To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may make changes and updates by logging into your user profile and making such changes. Alternatively, you may request such changes by contacting Communio Foundation Customer Service using the contact information provided below.
    • In your request, clearly state what information you would like to have changed or updated. Communio Foundation will try to comply with your request as soon possible.
    • The deletion of Personal Information and other changes to the data retained by Communio Foundation as described above may result in the deletion or limitation of the Services Communio Foundation provides, including, but not limited to, maintaining and making accessible Communio Foundation classes, courses, videoconferences, and other Services. Communio Foundation may retain certain Personal Information to pursue legitimate business interests, fulfill contract obligations, conduct audits, comply with (and demonstrate compliance with) other legal obligations, resolve disputes, and enforce agreements.
  4. How to Change Your Personal Information
  • To make changes to the content of your Personal Information, or to request that we limit the use of your Personal information, you may request such changes by contacting Customer Service using the contact information provided below.
  • You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • In your request, clearly state what information you would like to have changed or updated. We will try to comply with your request as soon possible. Please note further that we are not responsible for updating information shared with third parties.
  • Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will delete your personal information from our records; and direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  1. Notices of Changes to Privacy Policy

In the event of any change to the Communio Foundation Online Privacy Policy, notice of such changes will be posted on the Communio Foundation website.  Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Communio Foundation website. Your use of the Communio Foundation website following these changes means that you accept the revised Online Privacy Policy.

  1. Contact Communio Foundation

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Communio Foundation Customer Service

platform@communio.org

12/2/2021