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Last Updated: 11/4/20

Welcome to the CORI Privacy Policy.

This Privacy Policy explains how information about you is collected, used, and disclosed by the Center on Rural Innovation, Inc. (“CORI” or “our” or “we” or “us”). This Privacy Policy applies to information we collect when you use our website (located at https://ruralinnovation.us/, including all associated web pages and mobile sites (collectively, the “Site”) or when you otherwise interact with us.  This Privacy Policy applies to your use of the Site and should be read together with, and is incorporated into, the CORI Terms of Service (“TOS”). All terms in this Privacy Policy that are defined in the TOS have the meanings ascribed to them in the TOS. 

Your use of the Site and/or provision of Personal Information (as defined in this Privacy Policy) via the Site constitutes your consent to our use, storage, processing, and transfer of that information in accordance with this Privacy Policy. By using the Site, you acknowledge and agree that you have read and accepted the terms of this Privacy Policy. Without prejudice to the generality of the foregoing, you expressly and unequivocally consent to: (a) the collection and processing of your Personal Information by us in accordance with the indicated purposes and this Privacy Policy and the TOS; and (b) the collection and processing of Personal Information on your behalf, as indicated in this Privacy Policy. 

We reserve the right to change this Privacy Policy from time to time and in our sole discretion. If we make any changes, we will notify you by revising the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). Any such changes will be effective immediately upon posting. Your continued use of the Site will constitute your acceptance of such changes. Because this Privacy Policy may change from time to time, it is important that you regularly review this Privacy Policy to ensure that you are updated as to any changes. We encourage you to review the Privacy Policy whenever you access the Site to stay informed about our information practices and the ways you can help protect your privacy. This Privacy Policy, and any posted changes to its terms, shall remain in full force and effect while you use the Site. 

As provided in the TOS, the Site is intended for access and use by United States residents only, and it is not intended for use by anyone under 18 years of age.

COLLECTION OF INFORMATION 

Personal Information

“Personal Information” includes any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier, or one or more factors specific to you. Personal Information includes pseudonymized Personal Information but excludes anonymous information or information that has had the identity of an individual permanently removed (“deidentified”).

The type of information we may collect could include, but is not limited to, your name, email address, postal address, phone number, mobile number, credit card information, and other personal, identifying, or preference information you choose to provide. 

Consent to Use of Personal Information

By accessing or using the Site, you are consenting to have your information, including Personal Information, transferred to, processed, and stored in the United States.

If you are providing Personal Information to us relating to a third party, you confirm that you have the consent of the third party to share such Personal Information with us and that you have made the information in this Privacy Policy available to the third party.

If you choose not to provide us with your Personal Information, you still may visit most of the Site. Please note, however, that you may be unable to access certain content on the Site or receive certain services or offerings otherwise provided.

How We Collect Information. 

We may collect information about you, including Personal Information, as follows: 

Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you fill out a form, make a donation, send us an email, sign up to receive email updates, sign a petition, sign up as a volunteer, create an account, schedule an event, participate in a contest or promotion, make a purchase or contribution, communicate with us via third party social media sites, request information, or otherwise communicate with us. We collect information that you provide when you communicate with us through the Site or otherwise (such as by email, phone, regular mail, or via our social media pages). We may collect your Personal Information if we monitor the Site. 

Information We Collect Automatically When You Use the Site. When you access or use our Site, we automatically collect certain information about you, including:

  • Log Information: We log information about your use of the Site, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Site.
  • Device Information: We may collect information about the computer or mobile device you use to access the Site, including the hardware model, operating system and version, device identifiers, and mobile network information.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that helps us to improve the Site and your experience, see which areas and features of the Site are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Site or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. For more information about cookies and how to disable them, please see “Your Choices” below.

Information We Collect from Other Sources. We may also obtain information from other sources and combine that with information we collect through the Site. For example, if you create or log into your account through a social media site, we will have access to certain information from that site in accordance with the authorization procedures determined by such social media site. We may also use such information for list matching purposes.

USE OF INFORMATION

We may use information about you, including Personal Information, for various purposes in accordance with the terms of the Privacy Policy in effect at the time of such use, including to:

  • Provide, maintain, and improve the Site;
  • Provide and deliver information you request, process contributions and transactions, and send you related information, including confirmations and invoices;
  • Send you confirmations, technical notices, updates, security alerts, and support and administrative messages;
  • Request feedback and otherwise contact you about your use of the Site;
  • Respond to your comments, questions, and requests and provide customer service;
  • Send you newsletters and otherwise provide you with information or services you request or that we think will be of interest to you, such as sending you information to keep you informed about various issues, events, resources, promotions, products, and services;
  • Determine your eligibility, including verifying your identity or determining your eligibility for certain aspects of the Site, such as promotions, services, products, which may include verification of you rage, date of birth, and state of residence;
  • Engage in internet-based advertising, including where we and our third-party partners may engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Site or on other sites, services, and mobile applications or on other devices you may use;
  • Communicate with you about this Privacy Policy or the TOS, changes to the Site, feedback requests;
  • Monitor and analyze trends, usage, and activities in connection with the Site;
  • Personalize and improve the Site and provide advertisements, content, or features that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; 
  • Carry out our contractual obligations, including any obligations arising from any agreement entered into between you and us, including the TOS; 
  • Help maintain the safety, security, and integrity of the Site, products, services, databases, technology assets, and business assets, and to help prevent and detect fraud;
  • Administer and protect our business and the Site, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, protecting and enforcing our legal rights, protecting our company;
  • Comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities; responding to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
  • Carry out any other permissible purpose for which the information was collected.

SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy.

We reserve the right to disclose and share your Personal Information: 

  • With third-party service providers, vendors, consultants, and volunteers  (together, “service providers”) engaged to assist us in providing the Site, including the content, to you or to carry out one or more of the purposes described above or in the TOS. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance and are contractually required to protect Personal Information disclosed by us and to comply with the general privacy principles described in this Privacy Policy. When we use such service providers, we provide limited access to your information so that such service providers can perform the tasks on our behalf;
  • With business advisors, such as accountants and lawyers, who assist us in carrying out our business activities;
  • In response to a request for information (such as a subpoena, warrant, or other court order) if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation, or to respond to an emergency situation;
  • If we believe your actions are inconsistent with the spirit or language of the TOS, any user agreements or policies, or to protect the rights, property, or safety of CORI, our employees, volunteers, or others persons associated with CORI;
  • In connection with, or during negotiations of, any reorganization, formation of new organization, asset sale or transfer, financing or lending transaction, or in any other situation where personal information may be disclosed or transferred as one of the assets of CORI; 
  • With a third party if we have reason to believe that disclosing Personal Information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users, or anyone else who could be harmed by such activities.
  • With governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud that has already taken place. The information is not provided to these companies for marketing purposes. 
  • With your consent or at your direction, including if we notify you through the Site that the information you provide will be shared in a particular manner and you provide such information.

Deidentified or Aggregated information. We may share statistical, deidentified, or aggregated non-Personal Information about our users with business partners, affiliates, sponsors, and/or other third parties, including but not limited to Google Analytics. Such data may be used to customize our website content to deliver a better experience to our Users. You may opt out from Google Analytics implementations and features that we use (see the “Your Choices” section of this Privacy Policy here. 

Social Sharing Features. The Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on the Site with other media, and vice versa. The use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features. 

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow third parties to use cookies or other technologies to provide analytics services and to serve ads on other websites based on your visits to this site and other sites across the Internet. These entities may collect information about your use of the Site and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by CORI and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your online activity. 

For example, we may use remarketing with Google Analytics or other remarketing tools to advertise online. This enables third-party vendors, including Google, to show our ads on sites across the Internet. Such third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our website. For information on how you can opt out of Google’s use of cookies for interest-based ads please visit Google’s Ads Settings.

For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.networkadvertising.org/managing/opt_out.asp and
www.aboutads.info/choices.

SECURITY

The Site uses security measures at least equal to those reasonably expected in the industry, to protect against the loss, misuse, and alteration of your Personal Information under our control. These measures include commercially reasonable industry-standard physical, administrative, and technological methods to protect your Personal Information. 

We cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your Personal Information for improper purposes. In the event that any information under our control is compromised as a result of a breach of security, we will take commercially reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Please keep in mind that you are responsible for the security of any Personal Information in your control. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personal Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place such as a library or Internet cafe. When you see either a solid key icon or a locked padlock icon at the lower portion of your browser window, this indicates that you site is secured through Secure Sockets Layer. If you do not see one of these icons, please contact your Internet service provider.

YOUR CHOICES

Cookies. Most web browsers are set to accept cookies by default. If you prefer, you may be able to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Site.

Promotional Communications. You may opt out of receiving updates and newsletters from CORI by following the instructions in those emails or by emailing us hello@ruralinnovation.us. If you opt out, we may still send you other types of emails, such as those about your use of the Site or any donations or transactions.

CONFLICT IN TERMS

Some browsers utilize privacy enhancing technology to translate our Privacy Policy into a computer readable format and then translate it back into human readable format for you to read. This translation back into human readable format is often referred to as a “Policy Summary.” To the extent that this Policy Summary is inconsistent with, fails to address, or addresses an issue not raised in our Privacy Policy, you should rely on our Privacy Policy as it is the controlling authority.

NOTICE TO USERS OUTSIDE THE UNITED STATES

As detailed in the TOS, the Site is designed to be used by residents of the United States. If you are a user located outside of the United States, be advised that any information you enter on the Site may be transferred outside of the European Union or your country to the United States of America, which may not offer an equivalent level of protection to that required in the European Union or your country. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. By using the Site, you unambiguously consent to the transfer of all such information to the United States of America, which may not offer an equivalent level of protection to that required in the European Union or your country, and to the processing of that information by CORI on our servers located in the United States.

STATE SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please see below for disclosures that may be applicable to you:

Nevada

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at support@ruralinnovation.us with the subject line “Nevada opt-out.” 

Privacy Notice for California Residents

California Consumer Protection Act. Because CORI is a nonprofit charity recognized by the IRS as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, it is not subject to the California Consumer Protection Act of 2018 (CCPA). CORI recognizes the importance of respecting the privacy of those who visit the Site, and many of our privacy practices align with the requirements of the CCPA, as outlined below. Any terms defined in the CCPA have the same meaning when used in this CCPA section of this CA Privacy Notice.

CA Consumers’ Requests and Choices.

Request for access to specific information and data portability. We will make commercially reasonable efforts to address your 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, as provided below, we will make commercially reasonable efforts to 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: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Request for deletion. We will make commercially reasonable efforts to address your request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, see below, we will make commercially reasonable efforts to delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.  
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Making requests for access, data portability, and deletion. To request access, data portability, and deletion as described above, please submit a verifiable consumer request to us by either:

  • Emailing us at support@ruralinnovation.us
  • Visiting https://ruralinnovation.us/contact/ and submitting an Online request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You also may make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability only twice within a 12-month period. 

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account (if applicable) sufficiently verified when the request relates to personal information associated with that specific account.

We will use personal information provided in a verifiable consumer request only to verify the requestor’s identity or authority to make the request.

Response, Timing, and Format. We will make commercially reasonable efforts to respond to a verifiable consumer request within a reasonable period of time. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will cover only the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination. We will not discriminate against you for making requests for access, data portability, or deletion. Unless permitted by the CCPA, we will not: 

  1. Deny you goods or services.
  1. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  1. Provide you a different level or quality of goods or services.
  2. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that if you request that we to delete or restrict information, some functionality of the Site may be inhibited, and any subsequent interaction with the Site after deletion may require new requests for action on your data.

Other California Privacy Rights. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@rurainnovation.us.

CONTACT US

To change your Personal Information or preferences (such as to modify your Personal Information, opt out of or change your preferences regarding receiving communications or information, please send an email to support@ruralinnovation.us.

For legal matters, including notices of violation of this Privacy Policy: 

Dunkiel Saunders Elliott Raubvogel Hand PLLC

PO Box 545, 91 College St.

Burlington, VT 05402-0545

Attention: Liz Kleinberg

(802) 860-1003, lkleinberg@dunkielsaunders.com

Please note: When you contact us, provide your name and address exactly as it appears on correspondence you have received from us. 

You are entitled to make an anonymous complaint or inquiry in relation to this Privacy Policy or your privacy rights; however, we may require you to identify yourself if required by law or it is impracticable for us to address your matter otherwise.