Privacy Policy

Effective Date: July 1, 2018

This Privacy Policy describes how Centro Community Partners (“Centro,” “we”, “us”) collects and processes information.

YOUR PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY TO LEARN ABOUT THE INFORMATION THAT CENTRO COLLECTS FROM OR ABOUT YOU AND HOW CENTRO USES THAT INFORMATION. WHEN YOU SUBMIT INFORMATION TO CENTRO, YOU CONSENT TO THE PROCESSING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY AND TO OUR TERMS OF SERVICE.

In this Privacy Policy, to “process” means to perform any operation on Personal Information (defined in Section 3 below), whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

1. WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy applies to information collected by or through Centro’s business planning tool mobile application (the “Centro App”)and any affiliated website or application in which this Privacy Policy is posted or specifically referenced (collectively, “Services”). This Privacy Policy does not apply to information that is collected offline or directly from you by any third-party website, application or other online service that you access through the Services.

2. CHANGES TO THIS PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this page. As we add new features to the Services, we may amend this Privacy Policy. If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you at least 10 days in advance through the Services and/or by email so that you have time to stop using the Services before the amended Privacy Policy is in effect. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

3. INFORMATION WE COLLECT

When you use the Services, we collect two types of information: Personal Information and Usage Data.

In this Privacy Policy, “Personal Information” means any information that identifies or could be used to identify an individual. Personal Information does not include aggregated information to the extent that an individual’s identity cannot reasonably be derived from it. Personal Information includes your contact data (name, telephone number and email address) and certain (but not all) Usage Data (defined below). Information that does not identify an individual or cannot be used to identify an individual is not Personal Information.

We define “Usage Data” as information about an individual’s activity on or through the Services that, by itself, does not identify the individual, such as browser type, operating system and webpages visited. Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Usage Data may, however, be Personal Information because it could be used to indirectly identify an individual. When Usage Data can indirectly identify you, we treat it as Personal Information.

We may link Personal Information and Usage Data or different types of Usage Data. We also may link publicly-available Personal Information, such as Personal Information available in public databases and through social networking websites. When the linked information identifies an individual person, we treat it as Personal Information.

4. HOW WE COLLECT INFORMATION

When you activate your account: If you use the Centro App to connect with a Centro Certified Advisor, you will be required to register for an account. When you register your account to use the Services, we collect name, email address, mobile number, gender and date of birth. We use this information to the Centro Certified Advisor.

When you use the Services: The information that we collect depends on how you use the Services.

When you use the Services, we collect information through our server logs. A server log is a list of the activities that a server performs. Centro's servers automatically collect and store information in server logs.

We collect information about your computer, tablet or mobile telephone (“Device”), such as model, operating system version, mobile network information, IP address and MAC address, browser type, internet service provider, system settings, the country and time zone in which your Device is located, metadata and other information stored on your Device, as permitted by your operating system and account settings. Centro may associate your Device information with your Centro account. Some of this information is collected using Data Collection Technology as described in Section 5 below.

When you enable the location settings on your Device, we may collect your geolocation information with your consent.

Through Partners: Centro partners with individuals and organizations that license Centro products and services to provide technical assistance services and access to capital to entrepreneurs and small businesses.

Through Service Providers: Third parties that assist us with our business operations also collect and process information through the Services and share that information with us. For example, service providers collect information to help us detect and prevent fraud, process donations and support the functionality of certain features of the Services.

Through Public Areas of the Services: Centro may offer areas in the Services where you can post information about yourself and others, communicate with others or upload content. Whatever you post in a public area may appear on other websites or when searches are executed on the subject of your posting. Also, Personal Information you voluntarily disclose on publicly-viewable web pages can be collected and used by others. Centro cannot control who has access to public information or what they may do with the information you voluntarily post, so we encourage you to exercise discretion when you publicly post your Personal Information.

Through Data Collection Technology: We and our service providers use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”) to automatically collect information about you when you use the Services. Please read below to learn more about how Centro uses Data Collection Technology.

5. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

How We Use Data Collection Technology: Data Collection Technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud.

The Services use the following cookies:

  • Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
  • Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
  • Functionality cookies, which are used to recognize you when you return to the Services.
  • Interaction cookies, which allow you to recommend us on Social Media.

We also use Google Analytics, which is a Google service that uses Data Collection Technology to collect information about use of the Services and report website trends. This information, which Google may collect by tracking a user’s behavior across third-party websites, helps us to learn more about our users. You can learn about Google’s practices in connection with this enhanced tracking and opt out of it by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

We also may use other Data Collection Technology to collect information from the Device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your Device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your Device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Centro, do not respond to DNT signals.

6. HOW WE PROCESS PERSONAL INFORMATION

Centro processes Personal Information:

  • To set register your account with the Services;
  • To communicate with you;
  • To help you manage your account;
  • To prevent and investigate fraud and other misuses of the Services;
  • To protect our rights and property;
  • To operate, manage, secure and improve the Services;
  • To respond to your questions and to try to resolve problems with the Services; and
  • To complete transactions requested by you.

Centro processes Usage Data:

  • To analyze trends and gather broad aggregate demographic information;
  • To statistically monitor how many people are using the Services;
  • To develop, improve and protect the Services;
  • For audience research;
  • To audit and analyze the Services; and
  • To ensure the technical functionality and security of the Services.

7. HOW WE SHARE INFORMATION

Centro may share Personal Information collected via the Services to help us provide the Services to you or to comply with law, as follows:

  • Service Providers: We share information with our third-party service providers that help us operate the Services, such as for processing payments and donations, for logging in using Facebook or LinkedIn, and for connecting your app account with advisors and lenders. Centro will ensure that any service provider with which we share Personal Information agrees to safeguard it in substantially the same manner as Centro has described in this Privacy Policy and in accordance with all applicable laws.
  • Transaction: We may share and transfer Personal Information if we are involved in a merger, reorganization or dissolution.
  • When Required by Law: Applicable law may require Centro to disclose your Personal Information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant), government investigation or other legal requirements or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
  • Other Lawful Disclosures: We also share information if (i) disclosure would mitigate Centro’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Centro and its users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.

Centro may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”). Centro shares Anonymized Information with third parties and does not limit any third party’s use of the Anonymized Information.

Also, Personal Information you voluntarily disclose on publicly-viewable web pages can be collected and used by third parties that Centro cannot control. Please use caution when you publicly post your Personal Information.

8. OPTING OUT OR CORRECTING INFORMATION

If you do not wish to receive emails from us, please click the unsubscribe link in one of our marketing emails or email us at legal@centrocommunity.org.

To correct Personal Information about you that you believe is incorrect, please email us at app@centrocommunity.org.

Although we will try to do so, we may not be able to remove or correct your Personal Information in databases of third parties with which we have shared your information prior to your request. Please contact those third parties directly.

9. LINKED SERVICES

The Services may include links to websites and services that are operated by our business partners or other third parties (“Linked Services”). We try to connect you to Linked Services that are helpful to you. If you decide to visit a Linked Service, you are subject to its privacy policy, not ours. We encourage you to read the privacy policy of each Linked Service that you visit or utilize.

10. PROTECTION OF PERSONAL INFORMATION

We take precautions intended to help protect information that we collect and store. Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.

You are responsible for maintaining the security of your password. Access to the Services through your email address and password will be treated as authorized by you. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

11. HOW TO CONTACT CENTRO

Please contact us at legal@centrocommunity.org.

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