Last Updated: November 11, 2021
Career Technical Education (CTE) Foundation Sonoma County recognizes the importance of your privacy. This policy is intended to inform you about the information we collect from your visits to our website, blogs, and social media accounts (hereinafter collectively referred to as “website”), how we use that information, and with whom the information may be shared.
Who We Are
Career Technical Education (CTE) Foundation of Sonoma County (CTEF) is a nonprofit organization based in Santa Rosa California. We are a 501c3 corporation. Our mailing address is CTE Foundation, 1030 Apollo Way, Suite 200, Santa Rosa, CA 95407.
Scope of our Privacy Policy
This Privacy Policy applies to information that we collect online through our website. It does not apply to information that we collect by other means, such as information you share with us verbally, in writing, or in email or text messages.
Information We Collect from Website Visits
Information we obtain from your visits to our website can be broadly described as the personal information that visitors provide us and technical information that we collect through the use of technology concerning those visits.
Personal information
Visitors to our website have the opportunity to register for events, workshops or webinars, sign-up to receive newsletters or other publications, sign up for or apply for programs, respond to surveys or make donations. From our website, we will collect any information that you voluntarily provide us such as your name, email address, telephone number or mailing address, credit card information, your company or firm name, and other business contact information. We will also collect other types of information you might provide such as preferences as to the types of information, events, or publications which you would like to receive, as well as responses to surveys or questionnaires.
If you submit any Personal Information relating to other people to us in connection with the Site, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Consent and Withdrawing Your Consent
You are under no obligation to provide us with your personal information when visiting our website. Whether you provide any personal information is entirely voluntarily and is solely within your discretion.
You can withdraw your consent at any time to our possession or processing of any of the personal information you provide us. To do so, you can send an email to our Administrative Coordinator at at admin@ctesonomacounty.org or you can contact CTEF by mail sent to CTE Foundation, 1030 Apollo Way Suite 200, Santa Rosa, CA 95407.
Technical Information
We collect certain types of technical information provided by the browser of the computer, tablet or mobile device used when visiting our website, such as:
Usage Details, IP Addresses, and Browser Information.
When you visit our website, we collect technical information such as the identity of your Internet Protocol (IP) address, your computer or device’s operating system and browser type, geo-location data, and the pages of our website that you visit. Most browsers transmit this type of information to websites automatically. We collect this information to administer and manage our website, to ensure that it functions properly and to review aggregate information.
Cookies.
Like many other websites, our website uses Cookies. Cookies are small text files that are downloaded to the browser of a computer, tablet or smartphone used to visit a website. A cookie will identify your browser, help you log-in and improve the navigation of a website. We use cookies to help us to improve the performance of our website. cookies allow us to review the number of visitors to our website and a visitor’s usage patterns; to track key performance indicators such as pages visited, frequency of visits, downloads and other statistical information; whether a visitor views the mobile or desktop version of our website; to recognize you if you return to our website; to store information about your past visits, and to remember your preferences.
You may be able to disallow cookies by modifying the settings in your browser. To learn more about cookies, and how to disallow or manage them go to: http://www.allaboutcookies.org/ . If you choose not to accept cookies, you may be unable to access certain parts or pages or our website.
How We Use or Process Your Information
We may process the information you provide and that we collect via our website to:
- Fulfill or meet the reasons you provided us the information, including to process your donations.
- Provide invitations to events and grant opportunities, to register you for events at your request or to sponsor events at your request, to provide newsletters, publications, blogs, social media feeds, and marketing information.
- Improve, develop, modify, or support our website, products and services, to update and maintain email lists and for other internal purposes.
- To market our programs, services, grant opportunities, fundraising events, programmatic events and other organizational-related content to you.
We do not sell the personal information you provide us.
With Whom We Will Share Your Information
We may share the information you provide us on a confidential basis with the following categories of third parties such as contractors, vendors, or service providers that support our operations and our website, but only for those purposes. This may include, for instance, tracking registrations, confirming attendance, and providing your biographic information to attendees of our programs. When we disclose any personal information for these purposes, we require that the recipient keep the information confidential and not to use if for any other purpose.
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Site links. Please review any third-party privacy policies to learn how they handle your Personal Information. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us.
Third-Party Payment Services
We may use third-party payment services to process donations or other payments made through the Site. If you wish to make a donation or other payment through the Site, your Personal Information will be collected by the third-party payment service and will be subject to that third party’s privacy policy, rather than this Privacy Policy.
Other Uses and Disclosures
We may also use and disclose your personal information as we believe to be necessary or appropriate: (a) to comply with applicable law and respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others. In addition, we may use, disclose or transfer your information to a third party in the event of a reorganization, merger, assignment, or transfer of all or any portion of our assets or organization.
Use of the Site by Minors; Minors’ Privacy
We are committed to protecting the safety and privacy of young people using the Internet. We do not knowingly collect personal data from children under age 18 except as necessary and at the child’s request to be signed up for classes, career fairs, and other events relating to our educational mission. We believe that children should get their parents’ or guardians’ consent before giving out any personal data. If you become aware that we have collected personal data from a child without parental consent, please notify us promptly at admin@ctesonomacounty.org. If we become aware that a child under age 18 has provided us with personal data without parental consent, we will take steps to remove such personal data.
Jurisdiction and Cross-Border Transfer
The Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Sensitive Information
Unless we specifically request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Site or otherwise to us.
Privacy Notice for California Residents
The California Consumer Privacy Act (“CCPA” or “Act”) grants residents of the State of California certain privacy rights in their personal information. This Privacy Notice for California Residents (“Notice”) supplements the terms of our Online Privacy Policy explained above and should be read in conjunction with the terms of our Online Privacy Policy.
This Notice only applies to visitors and users of our website who are California residents (hereinafter “you” or “consumer”). This Notice does not apply to personal information collected from California-based job applicants, employees, owners, or contractors.
INFORMATION WE COLLECT
As explained above in our Online Privacy Policy, the information we obtain from visitors to our website fall into two distinct categories—the personal information that visitors provide us and technical information provided by the browser of the computer, tablet or mobile device used when visiting our website. To understand your privacy rights under the CCPA, you need to understand what personal information is covered by the Act.
PERSONAL INFORMATION
The CCPA defines personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Personal information under the CCPA, however, does not include:
- Deidentified or aggregated consumer information.
- Publicly available information from federal, state or local government records.
Other information is excluded from the scope of the CCPA:
- Medical or health information covered by the Health Insurance and Portability and Accountability Act of 1966 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CIMIA”).
- Personal information covered by the Gramm-Leach-Bliley Act (“GLBA”), the California Financial Information Privacy Act (“FIPA”).
- Personal information Driver’s Privacy Protection Act of 1994.
- Personal information collected, processed, disclosed or sold for use in a report or by the user of a report under the Fair Credit Reporting Act (“FCRA”).
The information immediately below identifies categories or examples of personal information covered by the CCPA, and identifies categories of information that we have collected from visitors to our website in the past twelve (12) months:
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.
Collected by CTE Foundation? YES
- 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.
Collected by CTE Foundation? YES
- 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).
Collected by CTE Foundation? YES
- Commercial information:
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected by CTE Foundation? NO
- 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.
Collected by CTE Foundation? NO
- Internet or other similar network activity:
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected by CTE Foundation? YES
- Geolocation data:
Physical location or movements.
Collected by CTE Foundation? NO
- Sensory data:
Audio, electronic, visual, thermal, olfactory, or similar information
Collected by CTE Foundation? YES
- Professional or employment-related information:
Collected by CTE Foundation? YES
- 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.
Collected by CTE Foundation? NO
- Inferences drawn from other personal information:
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Collected by CTE Foundation? NO
OUR USE AND SHARING OF PERSONAL INFORMATION
How we use and share personal information obtained by visits to our website is disclosed above in our Online Privacy Policy. As we explained above in our Online Privacy Policy and reiterate here, we do not and will not sell personal information we receive from visitors to our website.
YOUR CCPA PRIVACY RIGHTS
The CCPA provides California residents with the right to request that we disclose:
Categories of any personal information we collected about you.
Specific pieces of personal information we collected about you.
Categories of sources for any personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
Categories of any third parties with whom we shared your personal information.
Categories of any personal information we disclosed about you for a business purpose.
Your right to request that we delete any personal information about you that we collected from you, subject to certain exceptions outlined below.
Your right not to receive discriminatory treatment for the exercise of your privacy rights conferred by CCPA.
By availing yourself to any of the rights afforded in this Privacy Notice you are declaring that you are a California resident.
REQUESTS TO DELETE PERSONAL INFORMATION
You have the right to request that we delete any of your personal information collected from you. Once we receive and confirm your request, we will delete the information from our records unless an exception applies. The CCPA provides that we are not required to comply with a request to delete personal information if the information is necessary for us to:
Comply with a legal obligation.
Complete the transaction for which the information was collected, provide a good or service you requested, perform a contract with you, to fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or take actions reasonably anticipated in the context of our ongoing business relationship with you.
Detect security incidents, protect against deceptive, malicious, fraudulent or illegal activity, or to prosecute those responsible for that activity.
Debug products, services or applications to identify and repair errors that impair existing functionality.
Exercise free speech, to ensure the rights of others to exercise their free speech rights, or to exercise another right provided by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based upon your relationship with us.
Make other internal and lawful uses of the information that are compatible with the context in which you provided the information.
HOW TO EXERCISE YOUR PRIVACY RIGHTS
You can exercise these rights by submitting a request via email to admin@ctesonomacounty.org or by mail sent to CTE Foundation, Attn: CEO, 1030 Apollo Way, Suite 200, Santa Rosa, CA 95407.
You may make the request on your own behalf or on behalf of your minor child. Another person who is legally authorized to act on your behalf may also submit a request for you. Please describe your request in sufficient detail to allow us to understand the nature of the request, evaluate and respond to it. Please provide sufficient information with your request to allow us to verify that you are the person about whom we collected personal information, or an authorized representative of that person.
We will promptly acknowledge receipt of your request and begin our verification process.
HOW WE WILL VERIFY AND RESPOND
Before we respond to any request involving personal information, the CCPA requires that we confirm the identity of the person making the request, and if the request is made on behalf of another person, his or her authority to make the request on the other person’s behalf. We are not obligated to provide or to delete any information pursuant to your request if we are unable to adequately verify your identity or the identity of the person making the request on your behalf.
Accordingly, we reserve the right to deny any request where we are unable to satisfactorily confirm your identity. If you have authorized someone to make a request on your behalf, we reserve the right to deny the request if we are unable to adequately verify the identity of that person or if we are unable to verify that the individual making the request is authorized to act on your behalf.
We will attempt to verify your identity by matching any information provided in your request against the personal information already in our possession. If you have authorized someone to make a request on your behalf, we will attempt to verify the identity of that person. We will also seek to confirm that you have authorized that person to submit a request on your behalf, which may include requesting a copy of any written authorization or power of attorney for the request. This process does not require that you establish any type of account with us or sign up to receive any of our publications or services, or attend any of our programs.
The amount of information we may require in our verification process will depend on a variety of factors including the nature of your request, the type, sensitivity and value of the personal information in our possession, the potential risk of harm that could result from any unauthorized access to or deletion of your personal information, the likelihood that fraudulent or malicious actors would seek your information and whether the information provided to us in your request is sufficient to protect against fraudulent requests or being fabricated or spoofed. For instance, we will require more points of confirmation if you request that we disclose specific pieces of information rather than categories of information in our possession. Concerning a request to delete information, once we confirm your identity, we will separately confirm that you want the information deleted.
During our verification process, we may request additional information from you. Any information provided to the Firm during our verification process will only be used for purposes of verifying your identity or the identity and/or authority of the person making the request.
We will endeavor to respond within forty-five (45) days of receipt of your request. If, however, we are unable to respond within that time, we will notify you of the reason and the additional time needed to make our response. The CCPA permits us to extend the time of our response by up to an additional 45 days.
If we deny a request in whole or in part, we will endeavor to explain the reasons for our denial.
CCPA’S LIMITATIONS ON DISCLOSURES
We are not obligated under the CCPA to respond to any request where compliance or disclosure would violate an evidentiary privilege under California law, or conflict with federal or state law.
The CCPA, does not require that we provide personal information to a consumer more than twice in a twelve-month period.
Any disclosures we make will only cover the twelve (12) month period preceding the request.
We will not charge a fee to process or respond to your request and will provide information free of charge. Where a person’s requests are repetitive, manifestly unfounded or excessive, the CCPA authorizes us to either charge a reasonable fee that takes into account our administrative costs or refuse to act on the request and notify the person making the request our reason for refusing the request. If we determine that a request warrants a fee, we will explain our decision and will endeavor to provide you with a cost estimate.
Regulations proposed by the California Attorney General prohibit us from disclosing specific pieces of personal information if the disclosure creates a substantial, articulable and unreasonable risk to the security of that information or the security of our systems or networks. These proposed regulations further prohibit us from disclosing in response to a consumer’s request a Social Security number, driver’s license number, other government issued identification number, financial account number, any health insurance or medical identification number, an account password or security questions and answers.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. This means, for instance, that we will not deny you services, charge you a different price, including a discount or other benefit or impose a penalty for the exercise of your CCPA rights.
OTHER CALIFORNIA PRIVACY RIGHTS
The California Civil Code permits California Residents with whom we have an established business relationship, to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to admin@ctesonomacounty.org. You can also send a request by mailing a request to CTE Foundation. Please mention that you are making a “California Shine the Light” inquiry.
Visitors from Outside the United States
If you are visiting our website from outside the United States (“U.S.”), any information you voluntarily provide via our website and any technical information from the browser of your computer, tablet or mobile device will be transferred out of your country and into the U.S. where our law firm is located. The laws and protections available to the privacy of your personal information in the U.S. may significantly differ from the protections available in your country. Personal data transferred to the U.S. may be subject to lawful access requests by state and federal authorities in the U.S. If you do not want any personal information to be transferred to the U.S., please do not provide that information to us via our website.
Visitors from the European Union
On May 25, 2018, the General Data Protection Regulation (“GDPR”) went into effect in the European Union (“EU”). The GDPR extends certain rights to natural persons involving the privacy of their personal information.
We are the data controller for any personal information provided via our website. We do not have a data protection officer in the EU. Any information that you provide to us will be stored in the United States; we do not intend to transfer your personal data to another country or international organization.
We will retain any personal information that you provide via our website for seven (7) years from the date you provided or last updated that information, unless you request that information be deleted at an earlier date. If that information is subject to a litigation hold or is required to assert or defend a legal claim, then we will hold that information until the claim or action is finally resolved.
Under the GDPR individuals are granted the following rights:
RIGHT OF ACCESS
You have the right to ask what personal information we have about you in our possession. You have the right to obtain a copy of your personal data free of charge so long as it does not adversely affect the rights of others. We may charge a reasonable fee based on administrative costs for additional copies. The right of access includes the right to request that we update, correct or complete your personal information in our possession.
RIGHT OF ERASURE
You have a right to request that data be deleted or erased when it is no longer needed for the purposes for which it was collected or processed, when you withdraw your consent, when data is unlawfully processed, to comply with a legal obligation of the EU or a Member State, or when you object to the processing and we are unable to demonstrate compelling, legitimate grounds for the processing which overrides your rights, freedoms or interests. Personal data does not have to be erased when and to the extent it is necessary “for the establishment, exercise, or defense of legal claims.”
RIGHT TO RESTRICT PROCESSING
You have a right to restrict the processing of your personal data when you contest the accuracy of the personal data in our possession until we are able to verify its accuracy, if the processing is unlawful and you oppose its erasure and request restriction instead.
RIGHT TO DATA PORTABILITY
The right to data portability is triggered when processing activity was based on your consent, or was necessary for the performance of a contract, and the processing was carried out by automated means. This right, however, shall not adversely affect the rights of others.
AUTOMATED DECISION MAKING
You have the right not to be subjected to decision-making based solely on automated processing or profiling that either significantly affects you or results in some sort of legal effect. This right does not apply to decisions that are necessary for entering into or performing a contract with you or are based on your explicit consent.
RIGHT TO OBJECT TO PROCESSING
You have the right to object to processing when it is based on a “legitimate interest” of the controller or a third party, or to processing that occurs for direct marketing purposes.
WITHDRAWING YOUR CONSENT
You have the right to withdraw your consent at any time by submitting a request via email to admin@ctesonomacounty.org or by mail sent to CTE Foundation, Attn: CEO, 1030 Apollo Way, Suite 200, Santa Rosa, CA 95407.
RIGHT TO COMPLAIN
You also have the right to lodge a complaint with the supervisory authority about our data privacy practices where you reside.
HOW TO EXERCISE THESE RIGHTS
You can exercise these rights by submitting a request via email to admin@ctesonomacounty.org or by mail sent to CTE Foundation, Attn: CEO, 1030 Apollo Way, Suite 200, Santa Rosa, CA 95407.
We will review any requests we receive and will endeavor to respond in a timely manner. For security reasons, we may request specific information from you to help us confirm your identity before taking action on any request, and to ensure your right of access and the exercise any of GDPR right does not adversely affect the rights of others.
We reserve the right to refuse to act on a request, or to charge a reasonable administrative fee when a request is either manifestly unfounded or excessive because of its repetitive character.
Updates to Our Online Privacy Policy
We may change this Privacy Policy from time to time. The “Last Updated” legend at the top of this Privacy Policy indicates when this policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.
How to Contact US
If you have any questions about this Privacy Policy, please contact the CEO of the Career Technical Education Foundation by sending an email to admin@ctesonomacounty.org or by calling the CEO at (707) 708-7080 or by mail to CTE Foundation, Attn: CEO 1030 Apollo Way, Suite 200, Santa Rosa, CA 95407.
