Updated: October 4, 2022
Below are more details about how the Institute collects, uses, and stores personal information from and about you, and your rights related to your personal information.
Collection and Use of Information
The Institute collects information voluntarily given by users as well as automatically collected information as you navigate the website and any Services. For example, if a user signs up for a newsletter, we will collect an email address. If a user contributes to the Institute, we will collect a name, billing address, and information needed to complete a donation transaction.
The types of personal information we collect includes:
- Contact information (first and last name, organization, title, mail and email address, phone number, country of residence);
- Payment information (including payment card numbers and associated identifiers, billing address, and bank account information);
- Purchase and participation history, such as information about donations you have made, purchases, and events you have attended;
- Demographic data, such as your gender, age, location;
- Recordings from online events (audio and video);
- Account creation and log-in credentials for our online store (e.g., username and password);
- Survey responses, sharing public or private comments, and content submitted or publications; and
- Job application information (e.g., resume and cover letter).
Sensitive personal information: You may voluntarily choose to share sensitive forms of personal information with us, such as information regarding race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, or disability information. We may collect this type of “sensitive personal information” for event registration, employment/independent contractor agreements, surveys, or program participation. In some instances, such as for contractors, and where required by applicable laws or regulations, we require you to provide financial and tax information (i.e., W-8s) and COVID-19 or other vaccination and testing information. We collect this sensitive personal information as required by applicable law, such as with your consent or pursuant to another lawful basis for processing
Information collected from third parties: Your personal information that you provide to us to sign up for newsletters, to register for our programs, make a donation, and for other purposes, is stored in our third party service provider’s platforms or systems, and this data may be enriched or updated to ensure it is accurate and up-to-date to achieve the purpose for which it was collected. We also may use third party services to help us develop prospect lists for members and donors and obtain personal information about you from them. We also may purchase email mailing lists for certain groups of individuals that we would like to send our program and membership information. These lists are provided to us in compliance with applicable laws and any of our marketing communications include an unsubscribe option so you can opt out if you do not want to receive such communications. For more information on how we use information collected from third parties, see the section “Combining of Information” below.
How we use personal information:
We use the personal information collected to operate our Services including the Digital Properties, administer our programs and events, provide our products and services, and to help us personalize and continually improve your experience with our Services.
We use your personal information when you use the Services as follows:
- Responding to your inquiries;
- To collect and process donations or payments to the Institute;
- To provide access to publications or purchases made through the Aspen Store;
- Communicating with you about your account or transactions with us and sending you information about features on our Services or about the Institute;
- Communicating with you about changes to our policies;
- Personalizing content and experiences through our Services, including providing you with recommendations based on your preferences.
- Sending you newsletters, mailings, and information about programs, initiatives, activities, and events by email or another medium;
- Processing your contractor, fellow, honorarium agreement, grant application or employment application;
- Event or program registration;
- To receive event information via websites, mobile apps, email, push alerts, or social media;
- When you participate as a speaker, volunteer to assist the Institute, or apply to participate in an activity we organize;
- To record events or webinars;
- Optimizing or improving our programs, services, and operations;
- Profiling for member, participant and donor prospect research;
- Research and development;
- Verifying your account and account activities;
- Detecting, investigating, and preventing activities that may violate our policies or be illegal;
- Performing statistical, demographic, and marketing analyses of users of the website and our social media services and their usage patterns (e.g., interactions with content such as blogs or online posts);
- Managing our organization; and
- For other purposes disclosed to you at the time you provide personal information to us.
Disclosure of Information
The Institute may disclose your information in the following ways:
- Current or future affiliated or partner organizations such as other nonprofit organizations that share a similar mission to that of the Institute;
- Institute fellows, members and partners to connect them with each other, peers and to foster event participation and collaboration;
- Vendors, service providers, advertising agencies, or agents who perform functions on our behalf (e.g., contractors, CRM platform providers, event registration platforms, email marketing providers, analytics providers, donor prospect scan organizations, and payment card processors);
- as part of, including during negotiations or planning for, a business transfer, such as an acquisition or asset sale;
- to protect the safety, rights, property, or security of the Institute, the Services, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues;
- to prevent or stop activity which the Institute may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity;
Please note that we may also use and disclose information about you that does not identify you individually. For example, we may conduct research and publish reports that contain aggregated and statistical data about our programs, members, participants, donors and others. We may also disclose aggregated, anonymized information about users for marketing, advertising, research, compliance, or other purposes.
Combining of Information
We may combine personal information into a single data record in our CRM system gathered from our Services with information that we have received, gathered, acquired, or stored from other sources, both information collected offline by the Institute and information received from third parties—including information that currently exists in our files. We also use and/or combine information that we collect offline or receive from third-party sources (e.g., contact information from government funders or grantor information) to edit, enhance, and/or check the accuracy of your relationship record. For example, we obtain contact details and other personal information regarding media contacts and influencers from a variety of sources including Cision. If you wish to know more about how Cision collects and uses such information, please refer to Cision’s privacy notice.
The Institute may also use combined information and third-party tools (e.g., donor and member prospect services) for the purpose of finding prospective donors or members. We may also use email marketing lists provided by third party services to help us send communications related to membership, event participation or other program activities. We may also use this list information for list hygiene and other administration purposes.
Cookies and Other Tracking Mechanisms
Pixel tags display tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device, pixels are embedded on pages. We may use pixel tags (also referred to as clear GIFs or beacons), in connection with our Digital Properties to understand the activities of users of our Digital Properties, help us manage content, and compile statistics about usage of our Digital Properties. We or our third-party service providers may use similar methods in emails to help us understand email response rates and identify when our emails are viewed.
Cookies we use include:
- Strictly Necessary: Some cookies are essential to enable you to move around our Digital Properties and use their features, such as accessing secure areas of the Digital Properties via a personal log in. Strictly Necessary cookies are also used to manage technical processes like server load balancing, caching, and security; to anonymize user sessions; and to store your cookie preferences so that we can honor them. Without these cookies, we cannot enable appropriate content based on your permission level. You generally cannot opt out of these cookies.
- Functional: Functional cookies store data for essential website services such as account creation, online learning modules, and media players. They may also be used to customize the user interface, and to store settings, and other user-based preferences. These cookies may be set by us or by third-party providers whose services are used on our pages. If you do not allow these cookies, then some or all of these services may not function properly.
- Performance: We use our own cookies and/or third-party cookies to see how visitors use our Digital Properties in order to enhance performance and improve our site, according to best practices.
- Analytic: These cookies and other technologies allow us to understand how you interact with the Digital Properties (e.g., how often you use the websites, where you are accessing the websites from (e.g., country, state), the content that you are interacting with). Analytic cookies enable us to support and improve how the Digital Properties operates. For example, we use Google Analytics cookies to help us measure traffic and usage trends for the Digital Properties, and to understand more about the demographics of our users. We also may use web beacons to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns via HTML emails. If you do not allow Analytic Cookies, then we will not know when you have visited the Digital Properties and we will not be able to monitor its performance. For information on how to opt-out of Google Analytics, please see Google Analytics Opt-out Browser Add-on Download Page and Google’s privacy practices.
You may set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and interacted with the content. For example, web beacons in emails may be blocked by setting your email preferences to “Plain Text Only”.
- Social Media: We provide social media widgets on our Digital Properties that link to social media pages for the Institute, specific Institute programs, or our specific products and services. These social media services are not owned or operated by the Institute. If you click on the social media widget, you will be taken to our page and a cookie may be set by the social media service to enable you to share our content with your friends and networks. It is your choice whether to log-in to your social media account. These sites are governed by their own privacy and related policies. Please read them to understand how they may use your information.
- Targeted Advertising: These third-party cookies may be set for certain of our Programs through our Digital Properties by our advertising partners. Our programs may be targeting underserved or other individuals in interest groups to foster participation in our programs, events and membership. We may use a combination of data to determine interest groups, including, but not limited to, data you have provided to us, data collected through our Services, or combined information as described in the “Combining Information” section above. We target and measure the performance of ads to such interest groups both on and off our Services directly or through third parties for the purpose of delivering advertising that is more relevant to you and your interests (i.e., programs or events you may be interested in), limiting the number of times you see an ad, and measuring the effectiveness of advertising campaigns. These cookies may be used by those third party ad companies to build a profile of your interests and show you relevant ads on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. See below for information on how to opt out of these cookies.
- YouTube: The Institute uses the available privacy functionality in YouTube to display video content on YouTube. We have turned on “Privacy-Enhancing Mode” for YouTube videos displayed on the Digital Properties. This means that YouTube does not place cookies on a video embedded on the Site unless you press “play” to view the video. Although we have turned on the “no cookie option” for our YouTube pages, there are a small number of pages where an update to the default embed code does not change older or non-standard spots where YouTube is embedded. For more information, please see Google’s privacy practices. You may also view content on the YouTube website. To control your privacy settings in YouTube, please see YouTube Privacy Controls. It is your choice whether to log-in to your YouTube account. YouTube is governed by its own privacy and related policies. Please read them to understand how they may use your information.
Ways to Manage Cookies:
There are several ways to manage cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies, or to notify you when receiving a new cookie. Please note, however, that many of the cookies we use are “strictly necessary” cookies. By blocking or deleting them, you will not be able to access certain features of the Digital Properties. For more information about cookies and how to block them, please visit allaboutcookies.org.
In the U.S., the Network Advertising Initiative also offers a means to opt out of a number of targeted advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. See here to opt out of Google targeted ads and here to opt out of Facebook targeted ads.
The Institute has taken steps to help protect the personal information we collect and use; and we review the security practices of service providers trusted to process data for the Institute. We use physical, technical, organizational, and administrative safeguards for our Services designed to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information we collect through our Services. Our security controls are designed to maintain data confidentiality, integrity, and an appropriate level of availability. But no transmission and storage of data is completely secure and submissions are at your sole risk. As such, we cannot ensure or warrant the security of any information you transmit or provide through our Services.
Messages that you send to us by email, including by use of the contact us form on the Digital Properties, may not be secure, and use of email is not recommended for sending us confidential or sensitive information. DO NOT SEND ANY PERSONAL INFORMATION, INCLUDING, BUT NOT LIMITED TO, W-8S, W-9S, SOCIAL SECURITY NUMBERS, DRIVER’S LICENSE INFORMATION, OR PAYMENT CARD INFORMATION TO US VIA EMAIL.
You are responsible for notifying us immediately of any known or suspected unauthorized use(s) of your account, or any known or suspected breach of security, including loss, theft, or unauthorized disclosure of your account credentials, or any other personal information. Any fraudulent, abusive, or otherwise illegal activity on your account may be reported to appropriate law enforcement agencies by us. In the event of a confirmed security incident that involves Service user’s personal information, we will notify you, the respective regulator, law enforcement, and/or individuals of such incident as required by applicable law or where the Institute deems appropriate.
Links to Other Websites
Your Choices and Rights
European Union and European Economic Area:
For individuals located in the European Economic Area (“EEA”), the General Data Protection Regulation (“GDPR”) may apply and is a European Regulation concerning the use and processing of personal information. We are committed to processing your personal information (aka “personal data”) in compliance with the GDPR. We will use reasonable efforts to securely process all personal information in line with the rights specified under the GDPR, including the right:
- to view and obtain a copy of the personal information we maintain about you, except where it would contain legal privilege, or compromise others’ rights, be disproportionately burdensome, or be commercially proprietary;
- to amend or revise, or in some instances to provide supplemental information regarding, the personal information we maintain about you;
- to have the personal information we keep about you erased/deleted (also known as the “right to be forgotten”) subject to certain limitations;
- to object to the use of your personal information for direct marketing (e.g., targeted advertising), automated decision making and profiling;
- to restrict our use of the personal information we maintain about you;
- to transfer the personal information we maintain about you to another entity subject to certain limitations;
- to object to our use of the personal information we maintain about you; and
Certain U.S. states have consumer privacy laws that may provide you with similar rights or additional rights as found in the GDPR. The Institute is a nonprofit organization and is not subject to some of these laws including the California Consumer Privacy Act but follows many of the requirements. The Colorado Privacy Act (“CPA”) does apply to nonprofit organizations and regulates the use and processing of Colorado residents’ personal information. When applicable, we are committed to processing your information in compliance with the CPA. including the right:
- to opt-out from the sale or sharing of your personal information;
- to direct that sensitive personal information collected about you is limited to that use which is necessary for certain purposes;
- to request deletion of your personal information that we collected from you and retain, subject to certain limitations;
- to not be discriminated against for exercising any of the above rights; and
- to opt-out of the processing of personal information for the purpose of targeted advertising and profiling* in furtherance of decisions that produce legal or similarly significant effects.
How to Exercise Your Rights:
To exercise applicable rights your jurisdiction may provide, including the rights to opt-out of targeted advertising and profiling, contact us as specified in the Section “Contact Us” below or by emailing us at [email protected]. We will require that you verify your identity before exercising your individual rights.
*For your information, Profiling is defined in applicable laws generally as “any form of automated processing of personal data to evaluate, analyze, or predict, personal aspects concerning an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.”
The Institute will provide you with the information requested free of charge once in a twelve-month period. The Institute will inform you of any action taken, and if the Institute refuses to take action in response to your request to exercise a right, will provide you with a written explanation of its reasoning. You may appeal this response by contacting us as described in this Section. If you have concerns about the result of your appeal, you may contact the Colorado Attorney General if you are a Colorado resident. If you are in the EEA, you may file a complaint with the appropriate supervisory authority.
Please note that these rights are not absolute. Your request does not ensure complete or comprehensive removal, as the content or information may be retained subject to applicable law.
California Shine the Light Law: The Institute does not share information that identifies you personally with non-affiliated third parties for their own marketing use without your permission.
Do not track signals and requests: Do not track signals and requests are sent from your browser to websites you visit indicating you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. At this time, our Digital Properties do not honor do not track signals or requests.
We will send marketing and informational communications to individuals if they have affirmatively indicated they want to receive them by providing their contact information and selecting the appropriate boxes to confirm their choices. You may opt-out of these mailings, future marketing, and informational materials at any time by contacting us as noted below in the “Contact Us” Section, or by emailing us at [email protected] and indicating you changed your preference or clicking the unsubscribe or opt-out feature at the bottom of electronic marketing and informational materials. If you choose to no longer receive marketing information, we may still communicate with your regarding transactional or administrative topics such as your account and service requests.
Lawful Bases of Processing
We rely on one or more of the following legal bases to process personal information:
- the processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Digital Properties, and maintaining the Digital Properties’ safety, fraud prevention and security as described above;
- For the legitimate purpose of operating our business, including for convening and communicating with members, fellows, partners, donors, event registrants/attendees, speakers, participants, and users to improve and develop the Services;
- consent is provided by you for a specific purpose (i.e., targeted advertising, marketing, promotional communications, processing W-8s and W-9s); or
- the processing is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims.
International Transfer of Personal Information
The Institute is located in the United States including Aspen, Colorado, Washington, D.C. and New York City. We may store information received through or by our Services in the United States. If you are providing the information from another country, you give affirmative consent to this transfer and understand that the information will be transferred, stored, and used by the Institute and its service providers in the United States.
Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), our Services are not targeted to children under thirteen (13) years of age and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems, unless we are legally obligated to retain it. If you believe we have mistakenly or unintentionally collected information from a child under the age of 13, please contact us as noted below.
Changes to this Privacy Statement
Questions and comments should be directed to [email protected].
Data Privacy – The Aspen Institute
2300 N Street, NW
Washington, D.C. 20037