Privacy Notice

Effective Date: October 26, 2024.

This Privacy Notice explains how  Setser Group Community and its GCF Global program  (GCF , “we”, “us”, “our”) collect your personal information as you use on GCFGlobal.org (the “Website”), how we use this personal information, with whom we share your personal information, and your choices in connection with this.

The Data Controller, i.e., the party making decisions on the means and purpose of the processing of your personal information, is Setser Group Community located in Durham, NC, and its GCF Global program.

(1) COLLECTION OF YOUR PERSONAL INFORMATION

We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

• A. Information We Collect From You

If you choose to engage in the services offered on our Website, we will collect personal information from you. We collect personal information from you when you:

Sign-in/Create Account: When you create an account on the Website or sign-in to your account, we collect from you your identifiers (first name and last name) and account login information (email address, username and password). We use this personal information to create your account, communicate with you about our services, and facilitate your access to the Website. The legal basis for this is your consent. You may revoke your consent at anytime, with effect going forward, by making a withdrawal of consent to us through our Contact Us form. Once your account is created, we will store your username and password, and use it to facilitate access to your account. If you decide to provide additional information, we will collect your date of birth, gender, and favorite topics to learn about. We will use this information to provide learning resources that are most relevant to your demographic and interests. The legal basis for the processing of information collected is your consent and you can revoke it at any time, with effect going forward, by making a withdrawal of consent to us through our Contact Us form.

Contact Us: When you contact us with a question or comment through our “Contact Us” form, we collect, from you, your identifiers (email address) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any topics you inquire. The legal basis for this is performance of our contract with you. If you do not provide this information, we will not be able to respond to your correspondence and assist you with your inquiry.

GCF may also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION. GCF may also deidentify or aggregate the personal information for benchmarking purposes.

• B. Information Collected Automatically

In addition to the personal information you provide, when you use our Website, GCF automatically collects the following information via cookies and similar technologies:

• Usage information. This includes information such as: your time of visit to the Website, pages visited, search terms, actions taken, how much time you spend on each page, transactions and payment method and amount, or customer objects throughout the Website and frequency of access. We use this personal information to: (i) conduct analytics; (ii) enhance user experience; (iii) prevent fraudulent use of the Website; and (iv) diagnose and repair errors
• Device information. This includes information about the device you use to access our Website, such as browser type, browser language, hardware model, operating system, and your preferences. We use this personal information to: (i) conduct analytics; (ii) enhance user experience; (iii) prevent fraudulent use of the Website; (iv) diagnose and repair errors; (v) remember your preferences; and (vi) provide enhanced functionality.
• Location information. This includes information about your location, which may be determined through your IP address.

The legal basis for collecting this information is your consent. The legal basis for the placement of these cookies is your consent. You can revoke your consent by following the instructions in the YOUR PERSONAL INFORMATION CHOICES section below.

To collect this information, we use cookies and other tracking technologies. Cookies are small pieces of text sent by your browser to your device. Cookies can be persistent (cookies that remain on your device for a set period of time or until you delete them) or session (cookies that are deleted as soon as you close your browser). When you use or access the Website, we and our third party providers may place a number of cookies on your device. These cookies include:

• Essential. We use essential cookies which are necessary to authenticate users, prevent fraudulent use of the Website, and to allow the Website and its features to function properly. The legal basis for the placement of these essential cookies is that they are necessary for our provision of the Website. If you do not provide this information, we would not be able to provide the service.
• Functional. We use functional cookies to provide enhanced functionality and personalization, to remember your login information, to remember your preferences, to diagnose server and software errors, and in cases of abuse, track and mitigate the abuse. The legal basis for the placement of these cookies is your consent. You can revoke your consent by following the instructions in the YOUR PERSONAL INFORMATION CHOICES section below.
• Analytics. Analytics cookies allow us and our analytics provides to recognize and count the number of users to the Website, see how users interact with the Website and different functions, and when users are using the Website. We use this information to improve the Website. The legal basis for the placement of these cookies is your consent. You can revoke your consent by following the instructions in the YOUR PERSONAL INFORMATION CHOICES section below.

To control the information collected about you using cookies and other technologies see YOUR PERSONAL INFORMATION CHOICES below.

Particular third-party cookies on our Website to note include:

• Google Analytics. We use Google Analytics to collect information on your use of the Website to improve our Website. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to our Website or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy available here. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.
• Smart Look. We use Smart Look to collect information and analyze your use of the Website to improve our Website. We will collect a recording of your session on the Website, scroll behavior, click behavior, custom events, page navigation flow, browser type, country, device ID, device type, operating system, and session code errors. In order to collect this information, Smart Look may set cookies on your browser, or read cookies that are already there.

For information on how we use cookies, please see our Cookie Policy. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device. [For future use: To set your cookie preference (opt into and out of cookies)            please see our Cookie preference center.] The legal basis for the processing of information collected via these cookies is your consent and you can revoke it at any time, with effect going forward, by making a withdrawal of consent to us through our Contact Us form.

GCF may also use your personal information to perform automated decision-making to predict what lessons may be of interest to you. We use your Website browsing history (what lessons and courses you have visited) to offer additional lessons that may be relevant to you. To object to the automated decision-making related to your personal information, you may contact us at privacy@gcfglobal.org.

(2) HOW WE SHARE YOUR PERSONAL INFORMATION

General Sharing

GCF may need to make the personal information identified in this Privacy Notice available within GCF, with service providers, or with other third parties. These instances include:

• Within GCF. We may share your personal information with GCF subsidiaries for legitimate business purposes and general business management. The legal basis for this is our legitimate interest in carrying out our business efficiently. Upon your consent, we may also share your personal information with GCF subsidiaries for marketing purposes. You can revoke it at any time, with effect going forward, by making a withdrawal of consent to us through our Contact Us form.
• With Service Providers. We may share your personal information with our service providers that assist us in providing the Website. The legal basis is our legitimate interest in providing the Website efficiently. These service providers include our website and IT (Information technology) support and security, support ticket provider, email marketing provider, database provider, and email provider.

With Third Parties. We may need to disclose your personal information to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations. The legal basis for this is compliance with the law.

In the Event of a Corporate Reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. The legal basis for this is our legitimate interest in carrying out business operations efficiently.

(3) YOUR PERSONAL INFORMATION CHOICES

• Correct or View Your Information. You may access your account to correct or view certain personal information you have provided to us, and which is associated with your account.
• Cookies. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser's directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. For information on reviewing or deleting cookies from specific browsers, click on the appropriate browser: Firefox, Firefox IOS, Firefox Android, Safari, Safari Mobile, Chrome, Internet Explorer, Microsoft Edge, Opera. To find information relating to other browsers, visit the browser developer's Website. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our Website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your computer. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences.

• Opt Out of Online Advertising. Some of the companies that provide advertising services on our Services may participate in industry-developed programs designed to provide consumers with choices about whether to receive tailored ads that are based on your online activities. To learn more and to opt out of such targeted advertising from participating companies, please visit the websites of the Network Advertising Initiative, the Digital Advertising Alliance. To successfully opt out, you must have cookies enabled in your web browser (see your browser's instructions for information on cookies and how to enable them). Your opt out only applies to the web browser you use, so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser's saved cookies, you will need to opt out again.
• Google Analytics. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.
• Smart Look. You can opt out of Smart Look here.

(4) YOUR RIGHTS AS A RESIDENT OF NEVADA

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at privacy@gcfglobal.org. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

(5) RIGHTS OF INDIVIDUALS UNDER GDPR

Under the General Data Protection Regulation (GDPR), individuals are entitled to the following rights. The rights available to you depend on our reason for processing your information.

1. Right to access. You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process.
2. Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate or incomplete.
3. Right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
4. Right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances.
5. Right to object to processing. You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal information, which is carried out on the basis of our legitimate interests.
6. Right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you. Please note this only applies to personal information you have given us.
7. Right to lodge a complaint. You have the right to lodge a complaint with your Supervisory Authority.

In the event of death the above-mentioned rights referring to your personal data may be exercised by those who have their own interest in doing so, or act to protect you as an agent, or for family reasons deserving of protection. You may expressly prohibit the exercise of certain rights listed above by those entitled by sending a written statement to GCF at the email address provided below. The statement may be revoked or modified later on using the same procedures.

Please note that requests to erase data are subject to current legal and regulatory obligations on the storage of documents.

To exercise your rights, you may send an email at any time to privacy@gcfglobal.org.

(6) RIGHTS OF INDIVIDUALS UNDER THE GENERAL DATA PROTECTION LAW (LGPD)

Under Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD), individuals are entitled to the following rights:

1. Right to confirm the existence of the processing: You have the right to ask us to confirm we are capturing and housing your personal information.
2. Right to access: You have the right to ask us for copies of your personal information.
3. Right to correct incomplete, inaccurate, or out-of-date data: You have the right to ask us to amend your personal information if incomplete, inaccurate, or out-of-date.
4. Right to anonymize, block, or delete data: You have the right to ask us to block, delete, or deidentify your personal information.
5. Right to data portability: You have the right to ask that we transfer or provide a copy of your personal information to another service or product provider, by means of an express request, pursuant with the regulations of the national authority and subject to commercial and industrial secrets.
6. Right to delete: You have the right to ask that we delete your personal information.
7. Right to obtain: You have the right to obtain information about public and private entities with which we have shared your data.
8. Right to know: You have the right to have information about the possibility of denying consent and the consequences of such denial.
9. Right to revoke: You have the right to revoke of consent of the use of your personal information.

To exercise your rights, you may send an email at any time to privacy@gcfglobal.org.

(7) RIGHTS OF INDIVIDUALS UNDER THE DATA PROTECTION LAW

Under Colombia's Data Protection Law, individuals are entitled to the following rights:

1. Right to be informed: You have the right to be informed about the use of your personal information.
2. Right to access: You have the right to freely access your personal information. If your inquiry is greater than once a calendar month, we have the right to charge may charge only the shipping costs, reproduction and, where applicable, certification of documents. Reproduction costs may not be higher than the recovery costs.
3. Right to rectification: You have the right to ask us to amend your personal information if incomplete, inaccurate, or out-of-date.
4. Right to erasure: You have the right to revoke or delete your data if when processing it is not compliant with principles, rights, and constitutional guarantees.
5. Right to object: You have the right to object to the processing of your personal data.
6. Right to request evidence of consent: You have the right to obtain information about public and private entities with which we have shared your personal data.
7. Right to submit the SIC claims for violations of the Data Protection Law.

To exercise your rights, you may send an email at any time to privacy@gcfglobal.org.

(8) INTERNATIONAL TRANSFER OF INFORMATION

The personal information collected by the GCF will be transferred to countries or jurisdictions outside of the European Union or country of your residence, including to the United States of America, Brazil, and Colombia. The countries to which the personal information is transferred may not be as comprehensive as those in your country of residence. If this occurs, the transfers will be carried out pursuant to Standard Contractual Clauses approved by the European Commission incorporating such supplemental measures determined necessary by GCF.  For a copy of the Standard Contractual Clauses executed by GCF, please contact GCF's via the contact information in above.

(9) RETENTION

We keep your personal information for a limited period of time depending on the purpose for which it was collected. After such period, your personal information will be deleted or otherwise rendered anonymous in an irreversible way. The retention period is different depending on the purpose of the processing. The criteria used to determine our retention periods include (i) to execute transactions with you (such as completing your coursework), (ii) for as long as we have an ongoing relationship with you (such as maintaining your online account or sending you a newsletter); (iii) as required by a legal obligation to which we are subject; or (iv) as is advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

(10) DO NOT TRACK

We do not respond to Do Not Track (“DNT”) requests. Do Not Track is a preference you can set in your web browser to inform the Website that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, click here.

(11) INFORMATION SECURITY

We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

(12) CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is subject to change. Changes to the Privacy Notice will be posted on this page and will indicate the date the changes go into effect. Please check back frequently and review the Privacy Notice for any changes. If we make any changes that materially affect your privacy rights, we will notify you via email or by prominent posting on our Website.

(13) CONTACT US

If you have any questions or concerns on this Privacy Notice, please contact us at privacy@gcfglobal.org.

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