Privacy Policy

PRIVACY POLICY

Effective August 11th, 2020

Welcome!

This is the Privacy Policy (“Policy”) of Elevation Community Land Trust (“Elevation CLT,” “us,” “our,” or “we”), a Colorado non-profit corporation. You can contact us here.

This Policy describes how we collect, process, and share your Personal Data, as well as your rights and choices with respect to your Personal Data, and other important information. Please read this Policy carefully.

Scope of the Policy

This Policy applies to our website at elevationclt.org, including any subdomains or mobile versions (collectively, the “Site”). This Policy also applies if you provide information to us by email, mail, or otherwise (for example, if you upload completed forms to a link we provide to you).

This Policy does not apply to information processed by third parties, for example, when you visit a third-party website or interact with a third-party service, including forms or information you may provide to banks or other third parties in connection with purchasing home through Elevation CLT. We encourage you to review any third party’s privacy policy before disclosing information to them.

This Policy is incorporated into the Terms of Use governing your use of our Site. Any capitalized terms not defined in this Policy will have the definitions provided in our Terms of Use.

If you use our Site or otherwise provide completed applications, forms or other information to us, we will consider that to be your acknowledgement of the practices described in this Policy.

Processing of Personal Data

Personal Data We Process

We may process the following categories of data that relates to identified or identifiable individuals (“Personal Data”) (note, specific Personal Data elements listed in each category are only examples and may change):

Identity Data: Personal Data relating to an individual’s identity or representing that individual, such as your name, unique ID, etc.

Contact Data: Personal Data used to contact an individual, e.g. email address(es) or phone number(s).

Device/Network Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.

Inference Data: Personal Data inferred about personal characteristics and preferences, such as demographics, interests, behavioral patterns, psychological trends, or predispositions.

User Content: Any Personal Data you provide or attach when you complete a form, send an email or contact us through our Site or otherwise, including text, images, files, or other data.

How We Collect Personal Data

The Personal Data we process under this Policy comes from a variety of sources, that vary depending on the nature of processing and available technologies:

Data you provide to us: You may provide us with Personal Data directly, for example, when you send us a form you have completed, or sign up for a mailing list.

Data we create or infer: We (or third parties operating on our behalf) create and infer Personal Data based on our observations or analysis of Personal Data we process, and we may correlate this with other data we process about you.

Data collected automatically: We (or third parties operating on our behalf) may collect certain Personal Data automatically, for example, Device/Network Data is typically collected automatically through the use of cookies and similar technologies used on our Site.

Data we receive from others: We may receive Personal Data from third parties with whom we have a relationship. For example, we may receive the Personal Data we process from our third-party service providers.

How We Process Personal Data

We generally process your Personal Data in connection with the following activities and purposes, as well as for the general processing purposes described below. If we process Personal Data in a way not described in this Policy, this Policy will still apply generally, unless otherwise stated when you provide it.

Communications

You may contact us through our Site, email, phone or mail, or sign up for certain communications from us. In each case, we generally collect Contact Data, and any Identity Data and User Content that you provide in the registration form. In certain cases (such as when you submit a relevant inquiry to us) we may also send informational or marketing communications to you. In each case, we use this Personal Data as primarily necessary to provide the communications you receive. When you receive emails or other digital communications from us, we may also process Device/Network Data and Contact Data when you interact with our digital communications so that we can understand communication response and open rates.

Cookies and Similar Technologies

When you use the Site, you may interact with cookies and similar technologies that we operate on or that we allow access to our Site. We, and certain third parties, may automatically collect and process Device/Network Data and Inference Data when you interact with these cookies and similar technologies (e.g. by browsing a webpage on our Site). In cases where these cookies and similar technologies are controlled by third parties, we may receive this data from the third parties to the extent allowed by the applicable service provider or partner. Please note, some of these technologies can be used by third parties to identify you across platforms, devices, websites, and services. The privacy policies of third parties may apply to these third-party technologies and their own use of any Personal Data they collect.

Subject to Users’ rights and choices (described below), this data is processed as follows:

For essential or functional purposes that allow the Site to function, such as remembering passwords, or staying logged in during your session.

For analytics purposes, such as analyzing how the Site is used or performs, how users navigate through the Site, and in connection with improving the user experience and efficiency of our Site, understanding information about the devices used to access our Site, the demographics of visitors to our Site, what sites refer visitors to our Site, how often users visit our Site, and other similar purposes.

For social media marketing, so that you can see ads from us on social media services and interact with us on our social media pages, and other media on those services. These technologies may enable social media platforms to collect Device/Network Data and Inference Data about you when you browse our Site, as well as on third party pages, or the sites operated by those platforms. These platforms may link this data with other data they process about you and use that information to deliver ads that are more relevant to you based on content you have viewed, including content on our Site.

For ad retargeting and behavioral advertising purposes, so that you can see advertisements from us on other websites, and more relevant advertisements across the web. These technologies and the data they collect, may be used by advertisers to deliver ads that are more relevant to you based on content you have viewed, or inferences about you, which may be derived from data collected on our Site. These tracking technologies may also help prevent you from seeing the same advertisements too many times, and track whether you have interacted with or viewed ads delivered to you. This collection and ad targeting may take place on any third-party websites that participate in the ad network (e.g. any advertisements delivered by that ad network on a third-party website).

Purposes of Processing

In addition to the processing described above, we generally process Personal Data for several common purposes in connection with our organization. For example, we process your Personal Data:

To provide our services and fulfill our obligations to you
To provide, improve, and secure our services
To enable and improve our customer service

To comply with the law, and otherwise in the public interest.

Please see below for more information regarding the purposes for which we process your Personal Data.

Providing our Services and Fulfilling Obligations

We process any Personal Data as is necessary to provide the Site, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.

Internal Processes and Site Improvement

We may use Personal Data we process through our Site in connection with our improvement of the Site, understanding how our Site is used or functions, for customer service purposes, and for ensuring the security and stability of the Site. Additionally, we may use Personal Data to understand what parts of our Site are most relevant to Users, how Users interact with our Site, or how our Site performs. This processing is subject to Users’ rights and choices.

Aggregate Analytics

We process Personal Data as necessary in connection with our creation of aggregate analytics relating to how our Site is used and performs, to understand the use of our Site, demographics of our Users, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified. This processing is subject to Users’ rights and choices.

Compliance, Health, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally share Personal Data with the following categories of recipients:

Business Purposes: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other business interests or purposes, we may share your Personal Data with service providers who provide certain services or process data on our behalf. For example, we may use cloud-based hosting providers to host our Site or may disclose information as part of our own internal operations, such as security operations, internal research, etc.) When we disclose information for business purposes, we may disclose Identity Data, Contact Data, Inference Data, and Device/Network Data.

Affiliates: We may share your Personal Data with any of our current or future affiliated entities, for example, in order to streamline certain business operations.

Successors: Your Personal Data may be shared if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process.

Lawful Recipients: In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person, or in such other circumstances as may be required or permitted by law. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Users’ Rights and Choices

The state in which you reside may grant you certain rights in your Personal Data. To the extent you have such rights, we will honor them as required by law. It is possible for you to use portions of our Site without providing any Personal Data, but you may not be able to access certain features or view certain content. For example, you may have the following choices regarding the Personal Data we process.

Consent: If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

Direct Marketing: You have the choice to opt-out of or withdraw your consent to processing related to direct marketing communications. You may have a legal right not to receive such messages in certain circumstances. You may exercise your choice via the links in our communications or by contacting us. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Cookies & Similar Tech: If you do not want information collected using cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu, or any menus we may make available to you. You must opt out of third-party Site directly via the third party. For example, to learn more about or opt-out of Google’s analytics Site, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out. Please note, currently our Site does not respond to your browser’s do-not-track request.

Information Security

We implement and maintain reasonable security measures to safeguard the Personal Data we process. However, we sometimes share Personal Data with third parties. While we may require our service providers to follow certain security practices, we do not have control over and will not be liable for third parties’ security processes. We do not provide any guarantee that your Personal Data or any other information you provide us will remain secure. Generally, we retain Personal Data for so long as it remains relevant to its purpose or for so long as is required by law (if longer).

Changes to Our Policy

We may change this Policy from time to time. Changes will be posted on the Site with the effective date. Please visit the Site regularly so that you are aware of our latest updates. Your acknowledgement of these changes or use of the Site following notice of any changes (as applicable) indicates your acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns:

General inquires: info@elevationclt.org

Physical address: 1114 W. 7th Ave, Suite 101, Denver CO 80204

Phone: 720-822-0052