Centro Community Partners (“Centro,” “we,” “us,” and “our”) is committed to treating your personal information with respect and sensitivity. This privacy policy (this “Privacy Policy”) describes our information collection, use, and disclosure practices for information collected through our websites, applications, and online services (collectively, the “Sites”). This is part of our Terms of Use. By accessing, browsing, or using the Sites, you agree to this Privacy Policy and the Terms of Use. If you do not agree to every provision of this Privacy Policy and the Terms of Use, do not access, browse, or use the Sites.

In general, you can visit the Sites without telling us who you are or revealing any information about yourself. When you submit an inquiry via the Sites or register for an online account for the Sites (each, a “Site Account”), we may collect your name, email address, street address, telephone number (including your mobile phone number), taxpayer and immigration information, date of birth, bank account and payment card account information, and such other personal information you provide (collectively, “Personal Information”). We may also ask you to create log-in information for your Site Account, such as a username and a password. When you provide your mobile phone number, we may ask for your consent to receive direct dial calls, autodialed and prerecorded message calls, and text messages relating to the Sites at that number. You may withdraw your consent by contacting us as indicated below or by replying with “STOP” to any text message we send you. Your mobile carrier’s standard text message and data charges may apply; you are responsible for any fees charged by your mobile carrier if we contact you. By providing your Personal Information to us, you explicitly agree to our collection and use of such Personal Information as described in this Privacy Policy.

We (or our service providers acting on our behalf) may collect Personal Information about your access, browsing, and use of the Sites. This information includes information that may identify you as well as statistical information (“Analytics”) that does not identify you. Some Analytics may be correlated with your Personal Information. Usage Information may include:

Device Information: We may collect information about specific computers used to access the Sites (including, without limitation, a desktop, laptop, mobile phone, tablet, or other consumer electronic device) (each, a “Device”). Such Device information may include the hardware model, operating system version, unique Device identifiers, and mobile network information. We may associate your Device identifiers or phone number with your Site Account.

Log Information: When you access, browse, or use the Sites, we may automatically record or log information from your Devices and their software. This may include:

  • The Device’s Internet Protocol (“IP”) address;
  • Identification numbers associated with your Devices;
  • Device event information, such as crashes, system activity, and hardware settings;
  • Location preferences;
  • Application activity, such as app upload, app download, app installation, app uninstallation, app start, app play duration, app stop, app crashes, app network activity, and app resource consumption;
  • Date and time stamps associated with transactions;
  • System configuration information;
  • Metadata concerning your Android apps; and
  • Other interactions with the Sites.

Cookies: We use cookies to personalize the Sites for you and to collect aggregate information about usage of the Sites by all of our users. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your usage of the Sites. Cookies assign a random, unique numbers to your Devices to allow us to see how you use the Sites. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use on the Sites may include any of the following:

  • Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We use session cookies to grant our users access to content and to enable actions they must be logged into their Site Account to do.
  • Persistent cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve the Sites for our customers. For example, we may use a persistent cookie to associate you with your Site Account or to remember that your choices on the Sites, but this only works when cookies on the Sites are enabled.
  • Third-party cookies: We permit limited third parties to place cookies through the Sites to provide us with better insights into the use of the Sites or user demographics or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. For example, we utilize Google Analytics to analyze usage patterns of the Sites. Google Analytics generates a cookie to capture information about your use of the Sites that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify their cookie, but this will not be associated with any other data held by Google.

We may also permit third-party service providers to place cookies through the Sites, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

Your use of the Sites will be deemed to be your consent to the placement of cookies on your Devices. If you prefer not to receive cookies through the Sites, you can set your browser to: reject all cookies, to allow only “trusted” websites to set them, or to accept only those cookies from those websites you are currently browsing. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Sites and access, browse, or use them.

If you refuse cookies, this will limit system performance and may even cause certain features of the Sites to malfunction or not to work at all.

Web Beacons: We may collect information using web beacons. Web beacons are electronic images that may be used on the Sites or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and tell whether you open an email and act upon it.

Do-Not-Track: As of January 1, 2014, online operators must disclose (1) how the operator responds to web-browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about a consumer’s online activities over time and across third-party websites or online services; and (2) whether other parties may collect Personal Information about a consumer’s online activities over time and across different websites when he or she uses the online operator’s website or service.

The Sites do not use technology that recognizes “do-not-track” signals from your web browser.

We may engage third parties, such as marketing or Analytics providers, who may collect information about your online activities over time and across different Third-Party Platforms when you access, browse, or use the Sites.

The Sites are not designed nor intended to be attractive to use by children under the age of 18 (“Minors”). We do not knowingly collect Personal Information from minors. If you are under the age of 18, please do not submit any information to us.

The use of your information is subject to this Privacy Policy and our Terms of Use in effect at the time of use. The provisions contained herein supersede all previous notices or statements regarding our privacy practices with respect to the Sites.

We may use aggregated data (independent of any personal identifiers) for research and commercial purposes. This information includes what areas of the Sites our users visit most frequently. This information helps us to improve the Sites so that they are more useful and accessible to you.

We may use your Personal Information internally for our general commercial purposes including, among other things, to offer you our products and services and products and services of our affiliates and third parties that we think you may find of interest, but only Centro, its subsidiaries, and third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our subsidiaries and third-party service providers will be required to use any Personal Information we provide them only for that intended purpose.

We may use your email address to respond to your inquiries or to provide you information about the Sites. You can elect not to receive promotional emails from us either by “unsubscribing” to an email you receive or by contacting us as indicated below. If you unsubscribe, we may still send you non-promotional emails, such as emails about your Site Account or our ongoing business relationship.

We may share your Personal Information to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction or provide a service for you; (3) if the information is provided to comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; to enforce our Terms of Use or other agreements; or to protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, Personal Information may be one of the transferred assets); (5) if the information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); and (6) as otherwise described in this Privacy Policy.

We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of the Sites, to our affiliates and third parties.

The Sites may allow you to connect and share your actions, comments, content, and information publicly or with friends. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us as indicated at the end of this Policy or by following the “unsubscribe” instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your Site Account or transactions with us.

You are required to provide us with accurate and up to date information. We give you the ability to update your Personal Information at any time by updating your Site Account profile on the Sites or by contacting us as indicated below. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are keeping your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any of your Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

We have security measures in place in our physical facilities and in our computer systems, databases, and communications networks that are reasonably designed to protect information contained within our systems from loss, misuse, or alteration. When your payment account information is transmitted to the Sites or through the Sites, it will be protected by encryption technology, such as Secure Sockets Layer (SSL). We do not store payment account information.

To the extent permitted by applicable law, we are not responsible for maintaining the confidentiality of any Personal Information that you provide us. If there is information that you wish to protect from disclosure to others, do not provide it to us.

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Site Account and do not share them with others. If we receive instructions using your Site Account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Site Account or any other breach of security. We reserve the right to refuse to provide access to the Sites, terminate Site Accounts, or remove or edit Site content in our sole discretion.

When you use the Sites, you may be directed to Third-Party Platforms. We may also allow Third-Party Platforms to link to the Sites. We are not responsible for the privacy practices of any third parties or the content of Third-Party Platforms, but we do encourage you to read the applicable privacy policies and terms and conditions of such third parties and the Third-Party Platforms. This Privacy Policy only applies to the Sites.

We may hold Personal Information on our computers and systems in the European Union and in the computers and systems of our offices and datacenters in the United States, and Personal Information may be accessed by or given to our staff working outside the European Union. Your Personal Information may be processed by us in the United States, where laws regarding data protection may be less stringent than the laws in your country. By using the Sites and by providing any Personal Information to us through the Sites, all users, including, without limitation, users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such information in the United States.

Subject to applicable law, we may amend this Privacy Policy at any time and in our discretion by updating and posting a new version on the Sites or by otherwise notifying you of the revised terms. When we modify this Privacy Policy, we will post the revised version on the Sites and will update the date at the bottom of this Privacy Policy. Your use of the Sites after any such change constitutes your unconditional agreement to this Privacy Policy. For this reason, we encourage you to check the Sites frequently to review the current Privacy Policy in effect and any changes that may have been made to them.

The Sites are owned and operated by Centro. If you have any questions or suggestions with respect to this Privacy Policy, or if you wish to ask us to delete, correct, or show you your Personal Information as provided above, you can email us at legal@centrocommunity.org; write to us at 825 Washington Street, Suite 228, Oakland, CA 94607; or call us at (510) 830-3204.

Effective Date: March 18, 2014