Privacy policy.
Last Updated: February 2023
The Creative Ladder (referred to here as “The Creative Ladder”, “we” or “us”) is a nonprofit organization whose mission is to connect, inspire and elevate an inclusive new generation of creative industry leaders.
This Privacy Policy (“Policy”) describes how The Creative Ladder handles information that it collects about users (each, a “User” or “you”) on our website located at www.creativeladder.org (the “Site”), any applications, platforms or databases accessible through the Site, and any applications containing a link to this Privacy Policy (collectively, “Applications”), and the privacy protection we accord to personally identifiable information (“PII”). By using any of our Applications, you are deemed to agree to the terms of this Privacy Policy, so please do not use any of the Applications if you do not agree with these terms. For purposes of this Policy, PII about you means information that identifies you or that is reasonably related to information identifying you to which we have access.
We may update this Policy at any time. Any changes to the Policy will become effective upon the date of our posting of the revised Policy on the Applications. If the changes being made are material, we may notify you of the changes in a more prominent way, such as through an email. If you access or use an Application following the effective date of the revised Policy, you will be deemed to have accepted the Policy’s updated terms.
I. What Information Does The Creative Ladder Collect from You as a User?
The information we collect about you when you visit the Applications (“Your Information”)includes any information you actively provide, such as when you give us your contact information, as well as information you authorize another to provide about you or that you provide passively simply by accessing an Application.
SIGNING UP FOR OUR EMAIL LIST. If you wish to sign up for our email list, you will need to provide your first and last name and email address. You may also provide your phone number and mailing address, information about your professional background, information about your professional interests, and whether you would like to receive text/SMS updates.
REGISTRATION FOR OUR EVENTS, PROGRAMS AND SERVICES. If you wish to register for Creative Ladder events, programs or services on the Applications, you will need to provide your first and last name and email address. You may also need to provide your phone number and mailing address, information about your professional or personal background, information about your professional interests, whether you would like to receive text/SMS updates, and other information related to the event, program or service. You may be able to make payments for such event, program or service (where required) in our Applications. To facilitate such payments, you will need to provide your credit card or bank account information, first and last name, email address, mailing address, and phone number. We process payments through a third-party payment processor. Your Information is encrypted when sent to our payment processor and it is not stored in our Applications.
DONATIONS TO THE CREATIVE LADDER. You may be able to make donations to The Creative Ladder in our Applications. To facilitate such donations, you will need to provide your credit card or bank account information, first and last name, email address, mailing address, and phone number. We process donations through a third-party payment processor. Your Information is encrypted when sent to our payment processor and it is not stored in our Applications.
AUTOMATICALLY COLLECTED INFORMATION. The information we collect that you provide passively by using our Applications may include your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Application. We use Google Analytics to track traffic on our Applications to help us understand what Users find of interest on the Applications (see https://en.wikipedia.org/wiki/Google_Analytics). Google Analytics uses cookies and similar technologies on the Applications, so that we can compile statistics about our daily number of Application visitors, specific page views, or other patterns of use on the Application. We also use Bloomerang (https://bloomerang.co) for similar purposes. Cookies are small data files that a website stores on the hard drive of the device through which a website user connects to the website and can recognize the user’s visits by identification of the computer or device used to access an Application. We use only first party cookies, namely cookies that are installed by our Applications, and not third-party cookies that are installed by a different domain than the one the User visits.
We inform you about our use of cookies in the cookie banner of our Applications, where you are able to accept or reject all or specific categories of cookies before they are being placed to your device, apart from the cookies that are essential for the regular operation and security of our Applications. You can also set your browser to accept all cookies or to reject all cookies. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website. To learn more about cookies, please visit http://www.allaboutcookies.org.
II. How Does The Creative Ladder Use the Information It Collects from You?
A. PII. We may use the PII that we collect about you for any or all of the following purposes:
1. To establish and maintain donor lists. If you make a donation to The Creative Ladder through the Applications, we use the PII you provide to establish and maintain donor lists and to issue charitable gift receipts to donors.
2. To provide you with access to programs, events, resources and services. We offer various programs, events, resources and services that may be of interest to you, and we may use your PII to provide you access to those programs, events, resources and services. We may also use your PII to contact you regarding programs, events, resources and services for which you have specifically registered through the Applications.
3. To respond to your inquiries. If you pose questions to us or request information from us, whether by email or otherwise, we will use your PII to respond to you.
4. To offer you additional information. Once you have engaged with us, we want to provide you with information regarding our resources that may be of interest to you. We may use your PII to do that, such as, for example, by using your email address to email you information about our resources, programs, events, and services, only if you have opted-in to receive relevant emails from The Creative Ladder when you sign up for our email list. Our email messages that encourage you to use our resources and services will provide you with the opportunity to opt out of receiving additional marketing emails.
5. For our general business purposes. We use PII about you for our legitimate business purposes, such as to help us expand, refine and improve the Applications and to tailor them more to your interests and needs, including by requesting feedback from you, and for related internal purposes such as data analysis and internal audits.
B. Other Information. We use the information that is collected automatically about your use of the Applications to help us improve the Applications, such as by revising the Applications based on Application visitor trends, including usage of certain pages or functions on the Applications.
III. On Which Legal Basis We Collect and Use Your PII?
This Section refers to the Users located in the European Union (”EU”). For the purposes of EU data protection law, the General Data Protection Regulation (“GDPR”), we are the controller and responsible for the processing of your PII. When we collect and use your PII for the purposes described in the previous Section, the legal basis for the processing is as follows:
A. Except as otherwise set out below, the legal basis we rely on to process any PII is Article 6(1)(f) of the GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests. We believe we have a legitimate interest in conducting the activities necessary to supporting our mission as a nonprofit organization. In doing so, we considered your rights and expectations and have assessed that your interest, fundamental rights, and freedoms are not put at risk. When we collect and process your PII based on legitimate interest, you have specific rights outlined under the Section X below.
B. We also process your PII relying on the legal basis of Article 6(1)(b) of the GDPR, which allows us to process personal data when it is necessary for the performance of a contract to which an individual is party. For instance, this is the case when we request your credit card or bank account information to proceed with a donation to us or a payment for one of our programs, events, resources or services.
C. If we process PII for the purpose of complying with laws and regulations, the legal basis we rely on to process your PII is Article 6(1)(c) of the GDPR, which allows us to process personal data when it is necessary for compliance with a legal obligation to which we are subject.
D. If we ask for, and you provide, your consent before we process any PII for a specified purpose, this legal basis we rely on to process your PII is Article 6(1)(a) of the GDPR, which allows us to process personal data when an individual has consented to the processing for a specific purpose. This is the case when you opt-in to receiving our emails.
IV. With Whom Do We Share the Information We Collect About You?
The Creative Ladder shares the PII it collects from or about its Users in very limited circumstances, as follows:
A. Third-Party Service Providers. We share PII with unaffiliated third parties who provide us with services, and others who assist us with technology, data analysis, or similar services. We do not share PII with unaffiliated third parties for their own marketing purposes.
B. Acquirers or Assignees. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of The Creative Ladder or its assets, we may transfer any and all information that we collect from Application Users to the proposed or actual acquiring party or assignee.
C. Entities Entitled Under Law. We may disclose PII as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Applications, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of The Creative Ladder or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.
We may share information related to your usage of the Applications, but does not identify you personally, for any legitimate purpose.
V. How Do We Protect the PII We Collect?
We are committed to maintaining the security of your PII. We use reasonable organizational, technical, and administrative measures to help protect against the unauthorized access, disclosure, loss, theft, misuse, destruction, and alteration of the PII under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure.
The Creative Ladder will notify affected Users of any suspected or confirmed unauthorized access, disclosure, loss, theft, misuse, destruction, or alteration of their PII to the extent required by and in accordance with applicable state and federal laws. We may attempt to notify affected Users so that they can take appropriate protective steps, or we may post a notice on the website if a security breach occurs.
VI. How Long Do We Retain Your PII?
We will retain your PII for as long as is reasonably necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws that impose us legal, regulatory, tax, accounting or reporting requirements. We review the PII we hold at regular intervals and delete permanently any PII which is no longer necessary.
VII. Collection of PII by Others.
A. Tracking on Our Application. We do not allow others to collect the PII of visitors to our Applications by tracking individuals’ usage of our Application and other websites over time.
B. Other Websites. The Applications may contain links to websites operated by parties not affiliated with The Creative Ladder. These linked websites are not under our control and we are not responsible for the privacy practices or the contents of any such unaffiliated parties or their websites. If you provide PII through any such third-party website, the PII will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.
VIII. Use of the Applications by Children. Our Applications are not targeted toward or intended for use by minors and we do not knowingly collect PII from children under age thirteen (13). If we were to discover that we had collected any PII from a child under age 13, we would promptly delete it.
IX. International Transfers of Information. Our servers are located in the United States, and by using the Applications, you are deemed to understand and unambiguously consent to the collection and processing of your PII in the United States, with the awareness that the laws of the United States may not provide as much protection for PII as the laws of certain other countries or territories.
X. Your Additional Rights with Respect to Your PII. If you are located in the EU, you may have the following rights under the EU data protection laws with respect to the PII that we process within the scope of this Policy:
A. To request access to the PII we hold about you, including why we are holding it and who it could be disclosed to. There are some exceptions to the right of access, which means you may not always receive access to all of the PII that we process;
B. To have your PII rectified. You can ask us to rectify your PII;
C. To have your PII erased from our records if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there are no other legitimate grounds for processing it or you consider it has been unlawfully processed. You can ask us to erase your PII;
D. To object to the processing of your PII;
E. To have the processing of your PII restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it; and
F. To withdraw any consents you have given us to the processing of your PII. Such a withdrawal will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you.
You can exercise these rights at any time by contacting us by the email provided in the Section “Contacting Us” below. We will inform you about your request within two business days. You also have the right to complain to your national data protection regulator if you feel that your PII has been unlawfully processed. We would, however, appreciate the chance to deal with your concerns before you approach the national data protection regulator, so please contact us in the first instance by the same email.
XI. Contacting Us. If you wish to exercise your rights above, of if you have any questions or concerns related to this Policy or The Creative Ladder’s information practices, send us an email at info@creativeladder.org.