Foundation

Privacy Policy

Last updated: November 14, 2023

Celo Foundation, a Delaware nonprofit, nonstock corporation, file number 6646078 (the “Foundation”, “we”, or “us”) is the operator of any Website published by the Foundation, including, but not limited to, celo.org and celo.foundation (the “Websites”). The Foundation’s core purpose is to:

  • promote the use of the internet, open-source cryptographic networks and related technologies to globally support prosperity, financial inclusion, and environmental health through research, education and outreach;
  • serve its Members, and the larger community, to encourage the building upon, and contribution to, the open source Celo Platform and related functionalities; and
  • support and encourage a financial system that creates and supports conditions for prosperity for everyone.

As the operator of the Websites, we take the protection of your personal data seriously. We collect, process, and use your personal data in accordance with this privacy policy and in compliance with the General European Data Protection Regulation (“GDPR”).

This privacy policy (“Privacy Policy”) will provide you with information about the collection, processing, and use of your personal data when using the Websites, as well as when you interact with or participate in our events, programs, or other offerings (the “Services”).

For purposes of the GDPR, the Celo Foundation is the controller of your personal information. Where processing of personal information is undertaken by our affiliates, subsidiaries, and related entities, they are a joint controller with the Celo Foundation for your personal information.

In this Privacy Policy, “personal information” includes references to “personal data” as defined under applicable laws. Your use of the Websites and Services, and any dispute over privacy, is subject to this Policy and the relevant Terms of Use, including the applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy.

For any matters relating to data protection you may contact privacy@celo.org.

Marketing Choices

You have control regarding our use of Personal Data for direct marketing. In certain markets, you will need to expressly consent before receiving marketing. In all markets, you can choose to not receive marketing communications at any time. If you no longer wish to receive marketing communications from the Foundation, or remain on a mailing list to which you previously subscribed, or receive any other marketing communication, please follow the unsubscribe link in the relevant communications or contact us at privacy@celo.org.

Use of Personal Data

We use the personal information that we collect:

  • To make our Sites more intuitive and easier to use we use device data, cookies and other information that you may provide. This data is necessary for our legitimate interests in monitoring how our Sites are used to help us improve these Sites, and the information and tools available on these Sites.
  • To provide relevant marketing including providing you with information about events or services that may be of interest to you. It is necessary for our legitimate interests to process this information in order to provide you with tailored and relevant marketing, updates and invitations.
  • To consider individuals for employment and contractor opportunities and manage on-boarding processes we use job applicant data. The processing is necessary for the purposes of recruitment and on-boarding.
  • To carry out any other purpose for which the information was collected.

We may also use automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Websites.

Sources of Personal Information

We gather various types of personal information from individuals who access or use the Websites or our Services, from a range of sources, such as:

  • information you give us when you sign up for or otherwise use our Services;
  • information we receive from our Affiliates and third parties; and
  • information we collect automatically through cookies and similar technologies.

Types of Data Collected

Applicants for Internships or Employment. We collect and store personal information relating to individuals who apply to participate in our internships or for employment with the Foundation. The personal information collected and stored for internships or for employment with the Foundation, may include your name, address, or other contact information. In addition, if you choose to provide it, we may collect personal information regarding your membership in a diverse or underrepresented group.

Automatically Collected Information. In addition, the Foundation may automatically collect the following information about users’ use of the Websites or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; when you open certain emails we send; links you click; your IP address; your country of location; the length of time you visit our Websites and or use our Services; and the referring URL, or the webpage that led you to our Websites. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information.

Communications. When you communicate with us (via email, phone, through the Websites or otherwise), we may maintain a record of your communication.

De-identified Information. We may de-identify and aggregate certain personal information we collect such that the information no longer identifies or can be linked to a particular user or an individual data subject (“De-identified Information”), subject to the terms of any applicable user agreements. We may use this information to improve our Services, analyze trends, publish market research, and for other marketing, research or statistical purposes, and may disclose such information to third parties for these specific purposes.

Event Registration. When you register for one of our events (e.g., conferences, workshops, meetups) to participate as an attendee, a speaker or a sponsor, we collect personal information that includes name, company, contact information, and other information. We may also collect other optional personal information such as likes, interests, preferred pronoun, dietary restriction, size preferences for conference attire gifts and other background information. In addition, if you provide it, we may collect (1) personal information about disabilities, medical status or conditions and allergies in order to meet requirements for or provide appropriate accommodations for attendees, and (2) personal information about your citizenship, date of birth, and passport details if you request assistance from us with obtaining a visa letter to travel to one of our events.

Payment Information. To purchase Services (including registering for events, training and certification exams), users may be asked to be directed to a third-party site to pay for their purchases. If applicable, the third-party site may collect payment information directly to facilitate a transaction. The Foundation generally only records the result of the transaction and any references to the transaction record provided by the third-party site.

Social Media. We may use plug-ins from social networks. When you activate them by clicking on them, the operators of the respective social networks may record that you are on our Websites and may use this information. This processing of your personal data lays in the responsibility of these individual social media platforms and occurs according to their privacy policy. Please check with these individual social media platforms regarding their privacy policies. The Foundation is not responsible for data collected by these individual social media platforms. We only use these platforms to inform our community of updates and answer user questions.

How We Share Your Information

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third-party;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;
  • With your consent or at your direction; and
  • We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Transfer of Personal Data To Other Countries

We may transfer your Personal Data to countries outside your country of residence, including, but not limited to the United States, where Celo Foundation’s headquarters and some of its IT systems (including email) are located.

Third-Party Services, Applications, and Websites

Certain third-party services, websites, or applications you use, or navigate to from our Websites may have separate user terms and privacy policies that are independent of this policy. This includes, for example, websites owned and operated by our sub-processors or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.

Celo Foundation Sub-Processors

We use the following sub-processors to operate our Websites and Services:

Data security

We use appropriate technical and organizational security measures to protect your stored personal data against manipulation and unauthorized access by third parties. Please note that any data transmission on the internet (e.g. communication by e-mail) is generally not secure and we accept no liability for data transmitted to us via the internet. This information does not apply to the websites of third parties and the corresponding links given on our Websites and the Foundation assumes no responsibility or liability for these.

Purposes and Legal Bases for Our Using of Your Personal Information under GDPR

If you are an individual in the European Economic Area (“EEA”), we collect and process your personal information only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Websites or Services you use and how you use them. This means we collect and use your personal data only: - To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interest; - To fulfill contractual responsibilities; and/or - As otherwise in compliance with law. If you have any questions about the legal basis for processing, please contact us at the address listed in the “Contact Us” section or at privacy@celo.org.

Your GDPR Rights Regarding Your Data

If you are an individual in the European Economic Area (“EEA”), you have certain rights under GDPR, summarized below:

  • Right to confirmation. You have the right to obtain confirmation from the Foundation as to whether or not personal data concerning you is being processed.
  • Right to access. You have the right to obtain from the Foundation free information about your personal data stored at any time and a copy of this information.
  • Right to rectification. You have the right to obtain from the Foundation, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Right to erasure. You have the right to obtain from the Foundation the erasure of personal data concerning you as soon as possible, and the Foundation shall have the obligation to erase personal data without undue delay where an applicable grounds applies without exception.
  • Right to restriction of processing. You have the right to obtain from the Foundation restriction of processing in certain circumstances.
  • Right to object. You have certain rights to object, on grounds relating to your particular situation, to the processing of your personal data.
  • Right to withdraw data protection consent. You have the right to withdraw your consent to processing of your personal data at any time.

If you wish to exercise any of the aforementioned rights, you may at any time directly contact the responsible person at privacy@celo.org.

How Long We Retain Your Information

We strive to only keep your personal information only for the period of time needed for legitimate business purposes. In certain circumstances, however, legal or regulatory obligations may require us to retain records for a longer time than we otherwise would.

Minors

The Foundation does not knowingly collect, use or share any personal data from minors. If you learn that a minor has provided us with personal information without consent, please contact us.

Changes to the Privacy Policy

We reserve the right to change and update this Privacy Policy from time to time. If we make changes, you will be notified of the change by the date at the top of Privacy Policy, which will reflect the last date updated.

Please do not hesitate to contact us if you have any questions regarding this Privacy Policy by contacting us at privacy@celo.org.