Modified Date: March 1, 2023
This Privacy Statement (“Privacy Statement”) is published by the Center for Workforce Inclusion, Inc. (referred to in this Privacy Statement as “Center,” “we” “us” or “our”) to explain our privacy practices for any information we receive via https://centerforworkforceinclusion.org/ and any page or application controlled by us that links to this Privacy Statement (together,
the “Site”). Certain portions of this Privacy Statement also apply to other personal information collected or maintained by the Center, for example, under the “Rights Under the California Consumer Privacy Act” and “General Data Protection Regulation (GDPR)” sections below.
By using the Site, purchasing a membership or receiving any other services of the Center (collectively, the “Services”), you consent to the terms of this Privacy Statement. If you do not agree to the terms and conditions of this Privacy Statement, including having your Personal Information (as defined below) used in any of the ways described in this Privacy Statement, do not provide us with your information. Please note, however, that if you don’t provide us with your information, you may not be able to use certain parts or features of our Site or we may not be able to provide you certain Services.
The Center may update this Privacy Statement from time-to-time in our sole discretion by posting such revised Privacy Statement on the Site. Please note the Modified Date of this Privacy Statement at the top of the page. It is your responsibility to review this Privacy Statement regularly for any changes each time that you use the Site and/or the Services or provide us information.
This Privacy Statement also applies to the processing of personal data of individuals located in the European Union. If you are located in the European Union, if the processing of your data is subject to the laws of a member state of the European Union by virtue of public international law, if your information is otherwise governed by European Union Law, or the processing activities are related to the offering of goods or services to data subjects in the European Union or the monitoring of individuals’ behavior that takes place within the European Union, please review carefully the “General Data Protection Regulation (GDPR)” section below for more information regarding your rights and our activities relating to your personal data. If the GDPR section is applicable to your information, then other sections in this Privacy Statement still may apply to you but are subject to (and considered modified by) the GDPR section.
Description of Our Business
The Center for Workforce Inclusion is committed to bringing economic opportunity to low-income and other disadvantaged older adults. We trace our roots to the National Council of Senior Citizens, launched in 1962 to advocate for older Americans. We are now the only national entity dedicated exclusively to the workforce development needs of underserved workers 50+. Headquartered in Silver Spring, Md., near Washington, D.C., we are a 501(c)(3) non-profit organization headed by President and CEO Gary A. Officer and a board of directors. For the purposes of this Privacy Statement, registration of a Site account (an “Account”) to register as a user for purposes of purchasing a membership, accessing additional functionality, information or services or products from the Center including access through the client login page, shall be included in the definition of “Services”).
Collection and Use of Your Personal Information
We require Site visitors who register an Account to provide us certain Personal Information. Information we collect when you register to use our Services may include your name, email address, and other information that identifies you or that, in combination with other information we hold may reasonably be used to identify you (“Personal Information”).
We also may use the Personal Information you provide when you visit the Site, create an Account, purchase a membership, or contact us, to contact you to further discuss the product offerings and Services we provide to customers. You may choose to opt out of providing your Personal Information by not disclosing it to us or entering it when asked.
The Center processes the following types of Personal Information for the following lawful purposes and based upon the legal justification set forth in the parenthetical:
- Your submission of Account Information (CONSENT)
- Processing Personal Information in order to fulfill an order or provide Services (CONSENT, CONTRACT)
- Your submission of Personal Information when contacting us for customer service, to provide feedback or for other purposes not otherwise described here (CONSENT)
- Your submission of Personal Data to our third party vendors for Services (CONSENT, CONTRACT)
- Collection of Personal Information through the Site (CONSENT)
- Collection of resumes, employment applications or other information relating to employment (CONSENT)
- Processing payment for membership accounts (CONTRACT)
- Other information you voluntarily provide (CONSENT)
Legal Basis for Processing
We process your Personal Information with your consent or subject to the performance of a contract to which you are a party or, alternatively, in order to take steps at your request to enter into an agreement. You have the right to withdrawal your consent at any time.
Categories of Personal Information
Generally, we collect the following categories of Personal Information from you, directly or indirectly, or automatically when you use the Site or Services:
- Identifiers, including first and last name, email address, telephone number, physical address, cookies, IP address;
- Information in Customer Records, including first and last name, physical address, employment, and employment history;
- Legally Protected Characteristics under California or Federal Law, including age;
- Commercial Purchasing Information, including products or services purchased, obtained or considered;
- Internet or Electronic Network Activity, including browsing history, search history, IP address, cookies, clickstream;
- Geolocation, including IP address;
- Employment Information, including application file, personnel file, resume, benefits, employment history, employment status.
Disclosure of Personal Information
We do not sell, share, or disclose Personal Information to third parties, except when one or more of the following conditions is true:
- Service Providers and Contractors. We use third party providers and contractors to help us operate and improve the Services on our behalf, such as web-hosting companies, information technology providers, web-development consultants, analytics providers, delivery of goods and services, processing of credit card payments, billing and debt collection, customer services, marketing and communications services and event hosting; and
- Other Situations. We may use and disclose information outside of our day-to-day business practices and in ways unrelated to the Services.
- In the Event of Merger, Sale, Divestitures or Change of Control. We may transfer or assign Personal Information to an entity that acquires or is merged with us as part of a merger, acquisition, sale of ownership or assets, or other change of control.
- Affiliates. We may disclose Personal Information about you to our affiliates.
- Other Disclosures. We may disclose Personal Information about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms of Service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to our, your, or third parties’ rights, property, or safety.
- Authorized Representatives. If another individual is managing your account on your behalf (for example, a wife managing the account of her husband), as authorized by you or as a personal representative under applicable law, that person can view all Personal Information about you.
- With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.
Choices About Your Personal Information
You have choices about how we use your information. Please understand that if you choose not to disclose information to us, it may affect your ability to use some features of the Site and the Services.
We and our service providers may use information about your interactions with our Site to predict your interests and select the ads you see on and off our Site. This is known as interest-based advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance (“DAA”).
For more information about interest-based advertising and how you can opt out, visit:
Digital Advertising Alliance: http://www.aboutads.info/choices/
Network Advertising Initiative: http://www.networkadvertising.org/choices/
You may opt out of receiving marketing materials from us at any time by sending an email requesting such opt out to Contact@poweringopportunity.org or by clicking the “unsubscribe” or similar link in any marketing email. Even after such opt-out, you may receive additional emails for a short period of time while we process your request. We also may contact you by email or otherwise with information that is not primarily marketing, for example, regarding updates to the Services or information about your Account or any contracts or arrangements. If, at any time after registering your information, you change your mind about receiving information from us, send us a request specifying your new choice.
Do-Not-Track and Cookies
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity while you are using our Site and may track which website you visit immediately before or after accessing the Site.
California Residents’ Privacy Rights
This section is applicable to residents of California. If you are a resident of California, you have certain rights described below. The following do not apply to individuals who do not live in California on a permanent basis.
RIGHTS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83
A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by mailing us at 8403 Colesville Road, Suite 200, Silver Spring, MD 20910, emailing us at firstname.lastname@example.org, or calling us at (888) 664-1640. Please note that we are only required to respond to two requests per California Customer each year under Code Section 1798.83.
RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
This section of our Privacy Statement provides California residents with a comprehensive description of the Center’s online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California consumers regarding their personal information under the California Consumer Privacy Act (“CCPA”). This section applies to all California residents (but not including legal entities, such as companies). The section will not apply, however, if the Center does not collect any personal information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available). “Personal information,” for purposes of this section regarding the rights of California residents, does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records.
Rights under CCPA
Under CCPA, consumers have certain rights regarding their Personal Information, as described below.
- Right of Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
- The categories of Personal Information that we collected about you;
- The categories of sources from which the Personal Information is collected;
- The business or commercial purpose for collecting or selling Personal Information;
- The categories of third parties with whom we share Personal Information;
- The specific pieces of Personal Information that we have collected about you;
- The categories of Personal Information that we disclosed about you for a business purpose or sold to third-parties; and
- For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
- Right of Deletion: You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law.
- Right to Opt-Out: You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration. However, we do not sell or share any Personal Information for monetary payments. However, like many companies we do use services that help deliver interest-based ads to you and we may transfer Personal Information to business partners for their use. Because the definitions of ‘Personal Information,’ ‘share,’ and ‘sale’ under the California law are broad, making Personal Information available to these companies may be considered a “sale” or “sharing” under CCPA. You can opt out of such “sale” or “sharing” here: Do Not Sell or Share My Information. You may also contact us by using the Contact Us section below with a reference to “CCPA.”
- Right to Opt-In: We do not knowingly collect, share, or sell Personal Information of individuals under the age of 16.
- Right to Limit Use and Disclosure of Sensitive Personal Information: You may request specific limitations on further sharing, use, or disclosure of your Sensitive Personal Information that is collected or processed for purposes outside of those permissible under the CCPA.
- Right to Correction: You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.
If you would like to exercise your rights, please refer to the Consumer Requests and Verification section below with a reference to “CCPA.”
- Right to Non-Discrimination: We may not discriminate against you because you exercise any of your rights under the CCPA, including, but not limited to:
- Denying goods or services to you;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing a different level or quality of goods or services to you; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Selling, Sharing, and Disclosing Personal Information
We do not sell or share your Personal Information in exchange for monetary consideration. However, the definitions of Personal Information, ‘share,’ and ‘sale’ under CCPA are broad. Like many companies, we use services that help deliver interest-based ads and personalization to you, which may involve transfer Personal Information to business partners for their use, such as Google Analytics. Because the definitions of ‘Personal Information,’ ‘share,’ and ‘sale’ under CCPA are broad, making Personal Information available to these companies may be considered a “sale” or “sharing” under CCPA. Because of the breadth of these definitions under CCPA, we have provided opt-out links. You have the right to direct us not to sell or share your Personal Information. You may exercise your opt-out rights by contacting us using a method listed in the Contact Us section.
|Categories of Personal Information that May Be Sold, Shared, or Disclosed||Sources of Collected Information||Categories of Third Parties to whom Personal Information May Be Sold, Shared, or Disclosed||Business or Commercial Purpose of Selling, Sharing, or Disclosing Personal Information|
|Identifiers||Directly from you; Automatically when you use the Services||· Service Providers
|Additional Information Subject to Cal. Civ. Code § 1798.80||Directly from you||
|Legally Protected Characteristics under California or Federal Law||Directly from you||
|Commercial Purchase Information||Automatically when you use the Services||
|Internet or Other Electronic Information Activity||Automatically when you use the Services||
|Geolocation||Automatically when you use the Services||
|Employment Information||Directly from you; Automatically when you use the Site||
If you would like to exercise any of the rights provided under CCPA, please refer to the Consumer Requests and Verification section below with a reference to “CCPA.”
EU Privacy Rights
The Data Controller is the Center.
Identification of Primary Member State Supervisory/Data Protection Authority
You have the right to lodge a complaint regarding the processing of your Personal Data with us by contacting our Data Protection Officer listed above. You also may lodge a complaint with the Data Protection Authorities in the Member State where you habitually reside, work, or where an infringement occurred.
Processing Purposes and Legal Bases
The Center processes your Personal Data for the lawful purposes, and under the legal bases, set forth in the Processing Purposes section above.
The Center will not disclose Personal Data to a third party except as stated below:
We may disclose Personal Data to subcontractors and third-party agents. Before disclosing Personal Data to a subcontractor or third-party agent, we will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the GDPR; (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively process the personal information transferred in a manner consistent with the organization’s obligations under the GDPR; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the GDPR; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Supervisory Authorities upon request.
The Center also may be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements, or in the event of a merger or acquisition.
Rights under GDPR
Data Subjects have the following privacy rights under the GDPR:
- Right of Access. You have the right to obtain confirmation from us as to whether or not we process Personal Data from you, and you also have the right to at any time obtain access to your Personal Data stored by us.
- Right to Rectification. If we process your Personal Data, we use reasonable measures to ensure that your Personal Data is accurate and up-to-date for the purposes for which your Personal Data was collected. If your Personal Data is inaccurate or incomplete, you have the right to require us to correct it.
- Right to Erasure. You may have the right to require us to delete your Personal Data.
- Right to Restrict Processing. You may have the right to request the restriction or suppression of Personal Data.
- Right to Withdraw Consent. If you have given your consent to the processing of your Personal Data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
- Right to Data Portability. You may have the right to receive the Personal Data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
- Right to Lodge a Complaint with Supervisory Authority. You have the right to lodge a complaint with a data protection supervisory authority located in the European Union or UK. Further information about how to contact your local data protection authority is available at the website of the European Commission.
If you would like to exercise your EU privacy rights, please refer to the Consumer Requests and Verification section below and contact us as specified in the Contact Information section with a reference to “EU.”
Retention of Personal Data
For more information, please refer to the Retention Information section below.
Transfers to the United States
In using the Website, your Personal Data will be transferred to the United States. In December 2022, The European Commission published its draft adequacy decision recognizing the essential equivalence of U.S. data protection standards. The Center relies on Article 49 of the GDPR for transfers of data collected from Data Subjects in the EU and EEA. Transfers are made to Lavender only if the Data Subject has explicitly consented to the proposed transfer after having been informed of the possible risks of such transfers. Additionally, we transfer data as necessary for the performance of a contract between you as the Data Subject and Lavender as the Controller, to data processors who have an agreement with us that includes protecting your privacy and the security of your data, and in cases where your Personal Data is necessary for the implementation of pre-contractual measures taken in accordance with your requests.
Consumer Requests and Verification
You may request to exercise your rights of access, deletion, or correction under CCPA and GDPR by contacting us as described in the Contact Information section below. To help protect your privacy and maintain security, we will take steps to verify your identity before processing your request. If you request access to or deletion of your Personal Information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address. When you make such a request, you can expect the following:
- As required under applicable law, we will verify your identity. You will need to provide us with your email address and full name. We may ask for additional information if needed.
- We will confirm that you want your information accessed, corrected, and/or deleted.
- We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage or phone number listed below.
- We will respond to your request within 45 days upon receipt of your request. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
- In certain cases, a request for access, correction, or deletion may be denied. For example, if we cannot verify your identity, the law requires that we maintain the information, or if we need the information for internal purposes such as providing Services or completing an order. If we deny your request, we will explain why we denied it and delete any other information that is not protected and subject to denial.
You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as described in the Contact Us section below to make a request on your behalf. Even if you choose to use an agent, we may, as permitted by law, require:
- The authorized agent to provide proof that you provided signed permission to the authorized agent to submit the request;
- You to verify your identity directly with us; or
- You to directly confirm with us that you provided the authorized agent permission to submit the request.
Personal Information obtained by the Center is adequate, relevant and not excessive in relation to the purposes described in this Privacy Statement. The Personal Information is processed for purposes specified herein and will only be processed consistent with the purposes described herein. We will request only the minimum amount of information required to perform the applicable Services and will retain such information only for as long as necessary to provide the Services or for compatible purposes, such as to provide additional services, to comply with legal requirements, or to preserve or defend our legal rights.
Correcting & Updating Your Information
To update your information or discontinue the Services, email email@example.com. The Center will respond to your correction or update request within at most 30 days from the date of your request. You also may be able to update your information by logging into your Account.
Confidentiality and Security
We maintain reasonable safeguards to protect the Personal Information we collect. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
The Center may assign you a user ID and a password when you as part of your participation and access to the Site and your Account. Only you may use your user ID and password. You may not share your user ID and password with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur under your user ID. You play a role in protecting your information as well.
Social Media Platforms and Websites
Any information, communications, or material of any type or nature that you submit to any public areas of the Site, if any (e.g., any pages that display comments) or third-party websites (including, but not limited to any the Center-related or -controlled pages contained on a social media platform, application or website such as Facebook or Twitter) by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. the Center cannot control the actions of other users of any social media platform or website and we are therefore not responsible for any content or Submissions contained on such sites and platforms or public areas of our Site.
Visiting the Site from Outside of the United States
Your information may be transferred to, and maintained on, computers located outside of your state, province/territory, or country where the privacy laws may not be as protective as those where you live. If you are located outside the United States and choose to provide information to us, please be aware that we transfer your Personal Information to the United States and process and store it there. As a result, this information may be subject to access requests from governments, courts, law enforcement officials and national security authorities in the United States according to its laws. Subject to the applicable laws, we will use reasonable efforts to ensure that appropriate protections are in place to maintain protections on the Personal Information. By submitting your Personal Information, you consent to having your personal data transferred to, processed, and stored in the United States.
We do not knowingly collect or solicit personal information from children under the age of 13. By using the Site or Services, you represent that you are at least 13 years old. If you are under 13, please do not attempt to register for an Account or send any Personal Information about yourself to us. If we become aware that we have inadvertently received or collected Personal Information from a user of the Site who is under the age of 13, we will attempt to immediately delete that information from our files and records. Furthermore, we encourage users of the Site that are minors that are 13 years of age or older to ask their parents or guardians for permission before sending any information about themselves over the Internet.
If you believe a child who is under the age of 13 has provided us with Personal Information, please contact us at the address listed above.
- What is a cookie?
Cookies are small text files that are stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. For example, they can recognize you and remember important information that will make your use of a website more convenient (e.g., by remembering your user preferences).
- What cookies do we use?
Strictly necessary cookies.
These cookies are essential to the Site in order to facilitate our log-in process (if applicable) or enable you to move around it and to use its features. Without these cookies, we may not be able to provide certain services or features, and the Site may not function properly or perform as smoothly for you as we would like.
In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make while browsing the Site and to provide enhanced and more personalized content and features, such as customizing a certain webpage, remembering if we have asked you to participate in a promotion, and for other services you request such as watching a video or commenting on a blog. In order to permit your connection to the Site, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. If you access the Site from a mobile or other device, we may collect a unique device identifier assigned to that device (“UDID”), geolocation data, or other transactional information for that device. All of these features help us to improve your visit to the Site.
We and our service providers may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the Site and enable us to improve the way it works. Analytics cookies collect information about how you use the Site, for instance, which pages you go to most. The information allows us to see the overall patterns of usage on the Site, help us record any difficulties you have with the Site and show us whether our advertising is effective or not.
Social networking cookies.
These Social plug-in tracking cookies can be used to track both members and non-members of social networks for “additional” purposes such as behavioral advertising, analytics, and market research.
In some circumstances, we may work with third parties to provide services on our Site. For example, we use analytics services supported by third party companies who generate analytics cookies on our behalf. We may not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies also may transfer this information to other parties where required to do so by law or where such other parties process the information on their behalf.
Third-party advertisers and other organizations also may use their own cookies to collect information about your activities on our Site and/or the advertisements you have clicked on. This information, which may be combined with other information acquired from third parties, may be used by them to serve advertisements on our Site and third party sites that they believe are most likely to be of interest to you based on content you have viewed.
Third-party advertisers also may use this information to measure the effectiveness of their advertisements and to track aggregate usage statistics.
We may not control these third-party cookies, and their use may be governed by the privacy policies of the third parties employing these cookies. To learn about these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s website.
For more information about third-party advertising on the Site, see the section on Delivering Advertising in the Privacy Statement.
You can also learn more about controlling cookies in Section 4 below.
- How can you control cookies?
Please note that by disabling or blocking any or all cookies, some features of the Site may not operate as intended, or you may not have access to features or personalization available through the Site.
Analytics cookies can also be managed via the following links:
Google Analytics: http://tools.google.com/dlpage/gaoptout.
- How do we respond to DNT (“Do Not Track”) browser signals?
If you have any questions or comments about the information presented here, please forward them to us through the address on our Contact Us page or by calling (888) 664-1640.