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This Privacy Policy (“Policy”) describes how information may be collected and/or used by the Arnold Ventures, LLC (“AV”), Laura and John Arnold Foundation® (“LJAF”) and the Center for Effective Public Policy (“CEPP”) (AV, LJAF, and CEPP, collectively, “we,” “us,” or “our”) in connection with your use of the website available at www.advancingpretrial.org (the “Website”) and related content, services, features, and applications, including the APPR Community and APPR Learning platforms and services (collectively, the “Services”). The Policy does not cover information collected on sites, applications, destinations, or services linked to or from the Services that neither AV, LJAF, nor CEPP own or control.

We reserve the right to modify this Policy at any time. If we make material changes to this policy, we will post a notice on the Website. By continuing to use the Services after a notice of change has been so published, you are consenting to any such changes.

Information We Collect

A. Information You Provide Directly to Us
You may provide information directly to us if you register for the Services. Depending on the capacity in which a user registers, you may provide some or all of the following information: name; email address; physical address; telephone number; occupation or role; job title; employer; geographic location; and jurisdiction. We also may collect information from you if you register for trainings with us or otherwise submit an application to us or if you contact us through the Services. This information may include the personal information described above, along with additional questions about your organization and your use of the Services, if you choose to provide it. 

You also may provide information to us when you use APPR Community features, through which you may connect with other users, post questions, and share information, ideas, and resources with other users through the Services. If you choose to provide information via APPR Community, it may be viewable by other users. You should not include sensitive personal information in such posts. Although APPR exercises reasonable efforts to moderate the Services, we are not responsible for the content that you or other users may choose to post.

B. Information We Collect Automatically
We may collect certain information automatically about you, your device, and your usage of the Website, including through the use of cookies and other technologies described below. We do not collect information for third-party advertising, which is not allowed on the Website. We also do not use any tracking technologies for purposes of behavioral advertising.

  • Cookies, Clear GIFs, and Similar Technologies – We may use ​“cookies,” locally shared objects, and similar technologies on or in connection with the Services to maintain information about you. A cookie is a very small text document or image file, which often includes an anonymous unique identifier. We may use both ​“session” cookies and ​“persistent” cookies. A session cookie is temporary and disappears after you close your browser. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Website. Persistent cookies can be removed by following your web browser’s directions. More information can be found in our cookie notice.

    We may also use ​“Clear GIFs” (aka ​“web beacons” or ​“pixel tags”), digital fingerprinting, or similar technologies in connection with the Services or in communications with you. A Clear GIF is typically a one-pixel, transparent image located on a web page or in an email or other type of message which helps to verify an individual’s viewing or receipt of a web page or message.

    We use cookies, clear GIFs, and similar technologies to administer the Services, monitor site usage and trends, analyze how you use the Services, and maintain security. We do not use cookies or other tracking technologies so third parties can serve ads to you about their own products or services.
  • Website Usage Information – We may collect information about your usage and behavior on the Services, such as the content you view, the links you click, and how you were referred to our Services via other sites. We also collect your IP address and related information. We use this information for internal system monitoring and to administer the Services. This information may also be used to gather and aggregate broad demographic information and profile data.
  • Device Information – We collect information about the type of device you use when you access our Services, including details of your computer or mobile device, such as unique device identifiers and the browser you use to access our content.

We only retain your information for so long as it may be relevant for the purposes identified in this Policy unless a longer period of time is required by law.

How We Use Your Information

We limit our use of your personal information to the purposes described in this Policy. AV, LJAF, and CEPP may use your information in the following ways:

  • To provide, operate, monitor, maintain, and administer the Services;
  • For marketing purposes, such as communicating with you via email or to promote the Website;
  • To communicate with you, including to respond to inquiries you submit to us or to provide you with information when you sign up to receive information from us;
  • To provide and improve necessary functionality of the Services;
  • To promote the security of our Services and to investigate and prevent malicious, deceptive, fraudulent, or illegal activity, and enforce our terms and policies.
  • For legal, regulatory, safety, and compliance purposes, including compliance with any applicable law or regulations;
  • For other purposes about which we will notify you in advance or for which we receive your consent.

How We Share Information

1. Service Providers

LJAF and CEPP may use third-party service providers to help us operate and maintain the Services. Third-party service providers are contractually restricted from using or disclosing your information except as necessary to perform services on our behalf and pursuant to our instructions, or to comply with legal requirements. The third-party service providers that we may share your information with include:

  • Cloud hosting providers to provide data storage and processing services;
  • Website and system administrators to operate the Services;
  • Corporate and information technology service providers to facilitate business operations and communications;
  • Corporate entities associated with CEPP and LJAF, including Action Now Initiative, Action Now, Inc., and AV;
  • Analytics providers, like Google Analytics, to help us with analytics and perform analysis of how the Website is used or could be improved;
  • Professional services advisors to protect and manage our business interests;
  • Other suppliers, sub-contractors, partners, vendors, and service providers acting on our behalf.

We may use and disclose aggregate statistical information that does not identify or otherwise relate to an individual, such as overall patterns or demographic reports that reflect user behavior and interest in the Services.  Information relating to aggregate statistics may be collected through the use of third-party cookies and other third-party tracking devices.

2. Legally Compelled Disclosures

We may disclose any Personal Information you may have chosen to provide when disclosure is:

  • Reasonably necessary to comply with any applicable law or regulation;
  • Required by law to comply with legal process, a subpoena, court order, or government request;
  • Necessary to enforce our agreements and this Policy;
  • Necessary to protect the security or integrity of the Services;
  • Necessary to protect against harm to the rights, property, or safety of AV, LJAF, CEPP, you, or the public, as required or permitted by law; or
  • Necessary to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person. Where required or permitted by applicable law, we protect personal information by requesting protective orders or confidentiality agreements, redacting personal information from documents prior to production or disclosure, or other legally permissible means.

3. Transfer

We may share your information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer that it must use your personal information only for the purposes disclosed in this Privacy Policy.

Accessing Third-Party Services Through the Services

The Services may contain links to websites operated by third parties, such as social media websites, and your personal information may be collected by those third parties if you use their websites. Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do disclaim any and all responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Service). These links are provided to you for convenience purposes only, and you access them at your own risk. Any personal information collected by third-party websites will be governed by their respective privacy policies.

Minimum Age Requirements to Use the Website

The Services are not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us as described in the “Contact Us” section below. If we become aware that we have inadvertently received Personal Information from a visitor under the age of 13, we will take steps to delete such information from our records.

Security

We use commercially reasonable and appropriate administrative, physical, and technical safeguards to protect the information that we have about you from loss, theft, and unauthorized use, access, modification, or destruction.  We also require partners and third-party service providers acting on our behalf or with whom we share your information to maintain reasonable security and appropriate security measures. Notwithstanding our safeguards, it is impossible to guarantee absolute security. If you have any questions about the security of the Services, please contact us as described in the “Contact Us” section below.

Your Privacy Choices and Rights

A. Privacy Choices

You have certain choices and rights available when it comes to how we collect and use your personal information. Below is a summary of those choices and rights and how to exercise them.

  • Opt-out of marketing communications: You may opt out of receiving any marketing communications from us in the following way by clicking on “unsubscribe” at the bottom of any email or by updating your settings on the APPR Website.

 

B. Privacy Rights

Depending on where you are located, you may have certain rights in connection with personal information that we obtain from or about you. These rights may include, but are not limited to:

  • Right to Know the categories and specific pieces of your personal information we have collected in the previous 12 months. 
  • Right to Correct or Delete personal information we have collected from you. 
  • Right to Request Information about the collection, sale, and disclosure of your personal information from the previous 12 months. 
  • Right to Opt Out of the Sale or Sharing of Personal Information we have collected about you. However, please note we do not sell your personal information.
  • Right to Non-Discrimination for exercising any of your rights.

You may exercise these rights, to the extent they apply to you, by contacting us at https://advancingpretrial.org/appr/help/.

We may need to collect additional information to verify your identity and residence, and we may not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We fulfill requests within 45 days of receiving your request. Please note that your request may be limited in certain cases, for example, if complying with your request would conflict with: 

  • Federal, state, or local law; 
  • Regulatory inquiries; 
  • Subpoenas; or 
  • Exercising or defending legal claims.

Changes to Our Privacy Notice

We periodically review and update this Notice to describe new Services or changes to our practices. You can determine when this Notice was last revised by referring to the “Revised” date at the bottom of this Notice. We encourage you to review the Notice whenever you interact with us to stay informed about our privacy practices and the ways that you can help protect your privacy.

If we make significant changes to this Notice, we will notify you through a prominent notice on our Services or via email address or phone number you have provided. If you do not agree with the privacy practices disclosed in the Notice, we recommend you stop using our Site and Services.

Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like to review, delete, or update information we may have about you or your preferences, please contact AV and CEPP at https://advancingpretrial.org/contact-faq/.

Last revised May 2023