We take the protection of your personal data very seriously. That is why we, Counselors of Color Inc naturally comply with the legal provisions on data protection and we take appropriate steps to keep your data confidential. Furthermore, it is important to us that you know at all times what data we collect and how we process it. Please take a moment to read the following to find out more:

• who we are and how you can contact us
• which products this privacy policy applies to
• which personal data we process, for what purpose and on what legal basis
• to whom we transfer personal data
• how long we store personal data
• what rights you have in relation to the personal data we process about you.

This privacy policy serves to fulfil our obligation to provide information under data protection law. Where reference is made below to the fact that we process data on the basis of your consent, this naturally presupposes that you have given us your effective consent.

Person responsible and contact

Who we are and how you can contact us

The responsible party within the meaning of the General Data Protection Regulation  is:

Counselors of Color Inc

PO BOX 780061, Orlando FL, 32826 USA

You can reach us as follows:

E-mail: info@counselorsofcolorinc.org

Tel.: (305) 741-2071

Data category and purpose

What categories of data we process and for what purpose

Personal data

We process personal data that you disclose to us in connection with the use of our offer, as well as bank account data when paying to be registered as a provider or for becoming a member. This involves postal and electronic address and contact data (including phone numbers and e-mail addresses), Payment Data and details about you or in case of providers, about your company and services. We may also collect some financial data and data related to your gender, preferences, and basic information about you including the data you voluntarily submit to us. Also when you send us donations we process our data for the purpose of receiving your donation and likewise when you apply for a scholarship we process your data in accordance with your scholarship application only.

Automatic data collection through cookies

We use cookies to enable the use of certain features on our website. A cookie is a small text file stored in your browser’s cache that enables an analysis of your use of our web site. You have the option of preventing the cookie from being stored on your device by making the appropriate settings in your browser. It is not guaranteed that you will be able to access all functions of this website without restrictions if your browser does not allow cookies. For more general information on cookies please read on at allaboutcookies.org and for more details on the cookies we use in our Cookie Policy.

For what purpose we process data

We store the personal data that you disclose and that we research in our databases. In the following, you will find out for what purpose we use personal data and on what legal basis we do so.

Sending of e-mails and newsletters

On request, we send the newsletters to registered users. The newsletter is sent by e-mail on the basis of the information you provided during registration to the e-mail address you provided. We also use your e-mail address to inform you about our services and special publications, events etc. as part of our customer relationship. We send e-mails and newsletters based on our legitimate interest. You can object to this at any time. A link to exercise the objection is included in all e-mails that we send automatically or can be sent at any time to.

When you subscribe to our newsletter, we record the opening rate and which newsletter content you clicked on. We store this information to improve our newsletters.

Signing up for a membership or becoming a provider

We only use and store the data you provide to us in the course of your becoming a member or registering as a partner for the purpose of providing you with our services. The legal basis is thus, a contractual or pre-contractual measure.

Blog

Within the Blog you may be able to display certain information, share certain details, engage with others, exchange knowledge and insights, post and view relevant content. Content and data is  publicly viewable. You have choices about the information on your comment. You don’t have to provide additional information on your comment; however,information helps you to get more from our Services. It’s your choice whether to include sensitive information and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest.

Donations

The  personal data  collected in the course of making your donation will be processed for the following purposes: the Settlement of your donation with our payment service provider, and the Creation of a donation receipt. Depending on the selected payment method, your first and last name as well as your bank details will also be forwarded to our payment service provider .The legal basis for the processing is our legitimate interest.

Scholarship Applications

If you use our forms to apply for a scholarship, we process the information we receive from you as part of the application process.  Your data will initially be processed solely for the purpose of carrying out the application process. If your application is successful, it will become part of your personnel file and will be deleted in accordance with the rules applicable to personnel files. If we are unable to offer you a scholarship, we will continue to process your data for up to six months after sending the rejection in order to defend ourselves against any legal claims, in particular alleged discrimination in the application process.

The legal basis for processing data during the application process is your consent. The legal basis for data processing after a rejection is our legitimate interest.

As a rule, we do not require any special categories of personal data for the application process. We ask you not to provide us with any such information from the outset. If such information is relevant to the application process, we process it together with your other data. Your data will not be used by us for automated decision-making or profiling, nor will it be passed on to third parties. Your data will be processed by us or on our behalf.

Social Media Functions and Widgets

Within our online offer, functions and widgets of Instagram, Twitter,  Facebook, LinkedIn are integrated. When you click on or use any of those functions and widgets, your browser establishes a direct connection to Instagram, Twitter,  Facebook, LinkedIn. The function or widget then transmits log data to Instagram, Twitter,  Facebook, LinkedIn. This log data may contain your IP address, the address of the visited websites, type and settings of the browser, date and time of the request, your usage of Instagram, Twitter,  Facebook, LinkedIn ,as well as cookies. Those may also include the display of our post, the link to our profile, the possibility to interact with the posts and functions, as well as to measure users reach (so-called conversion measurement).

Recipients and transmission of data

We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support our online offer and our services.  Typically and unless otherwise stated in this policy, data may be shared on the basis of our contractual and pre-contractual obligations. Equally, if you have consented to it, or where there we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively). If we commission third parties to process data on the basis of a so-called “processing agreement”.

In relation to meta data obtained about you, we may share a cookie identifier and IP data with analytic service providers to assist us in the improvement and optimisation of our website which is subject to our Cookie Policy.

We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.

When paying by credit card or instant transfer, your credit card data (card holder, card number, card expiry date, card verification number) or account data are forwarded directly to our payment service provider (PayPal, Venmo,  Gofundme, Cash App) for processing the transaction, but are not stored by us.

Personal payment data is transmitted exclusively in encrypted form, using encryption systems that comply with the highest industry standards.

From time to time, we may be required by law or legal process to disclose your information. Transfers to governmental institutions or authorities will only take place within the scope of mandatory legal regulations.

Storage period

We delete data collected from contractual relationships after 10 years, all other data is deleted after three years at the latest in accordance with the Florida General Records Schedule.

Data subject rights

The rights you have are

• Right to information: On request, we will provide you free of charge with information about the scope, origin and recipient of the stored data as well as the purpose of storage. In the event of excessive requests for information (more than four times a year), we reserve the right to charge an appropriate fee.

• Correction: If, despite our efforts to ensure that the data is correct and up to date, incorrect information is stored, we will correct it at your request.

• Deletion: Under certain circumstances you have a right to deletion: for example in connection with an objection or in the event of unlawful processing of your data. If you request deletion of the information we hold about you, we will endeavour to comply with your request without delay.

• Restriction: You can also request restrictions on data processing for the same reasons that justify a claim for deletion – the stored data must, however, remain stored (e.g. for purposes of preserving evidence), but may no longer be used for other purposes.

• Objection/revocation: You can object to data processing that we carry out on the basis of a legitimate interest – as far as data processing for direct advertising is concerned, this right of objection is absolute. Consent given can be revoked at any time in writing and free of charge.

• Data portability: If you wish to transfer the data you have disclosed to another data controller, we will provide it in an electronically transferable format.

• Right to complain to the data protection authority: You also have the right to lodge a complaint with the supervisory authority within the  State of your residence, workplace or the place of the alleged infringement. However, you are also welcome to contact us directly at any time. You can exercise the aforementioned rights by contacting us.

Data security

We have set up organisational and technical security measures to protect your data, in particular against loss, manipulation or unauthorised access. We regularly adapt our security measures to ongoing technical developments. Intensive information and training of our employees and their commitment to data secrecy ensure that your data is treated confidentially.

We urge you to take all possible precautions yourself to protect your data while working on the Internet. Make it a habit to change your password frequently. We recommend that you use a combination of letters, numbers and special characters for your password and ensure that you use a secure, SSL-enabled browser to surf the Internet. If possible, log off completely after you have finished using a computer that you do not use exclusively alone and do not make your password available to third parties.

We use the industry standard SSL (Secure Sockets Layer) on all websites to encrypt your data. With SSL encryption, your data is alienated before it is transferred to our server in such a way that it cannot be reconstructed by third parties. In this way, the confidentiality of your details and your payment data is guaranteed during transactions over the Internet.

Modification of this privacy policy

We reserve the right to adapt the content of this privacy policy from time to time in order to be able to ensure protection in the future, in particular in line with new legal requirements or technical developments. We will inform you of any changes to our data protection guidelines by means of a pop-up window on our web site.

The use of your data is subject to the respective current version.

Valid from: August 2021