Privacy Policy

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Last Updated: May 20, 2021

1. Introduction

Welcome to the Rocky Mountain Microfinance Institute, (“we,” “us,” or “our”), website, https://www.rmmfi.org (our “Website”). Through our Website and via direct communication with our employees, we provide programs for entrepreneurs and related services including, but not limited to, business support courses and coaching (“Programs”), volunteer opportunities, receipt of donations, directory listings, and publications and information (collectively, our “Services”). At Rocky Mountain Microfinance Institute we value your privacy. This privacy policy (“Policy”) provides a comprehensive overview of how we collect, use, and share your Personal Information (defined below) when you access our Website, use our Services, or when we expressly direct you to this Policy. This Policy, as updated periodically, can be accessed at https://www.rmmfi.org/privacy-policy and supplements and is expressly incorporated into our Terms of Use, which can be accessed here. References herein to “you” or “your” mean our Website visitors, Program participants, volunteers, donors, and all other users of our Services.

This Policy is to inform you about the types of Personal Information we collect about you when you use our Website and Services, how we may use that Personal Information, with whom and how we may share that Personal Information, and the choices you have regarding our use of that Personal Information. By accessing, using, submitting information to, or otherwise using our Website and Services, you consent to and agree that we may collect, process, use, retain, share, and transfer your Personal Information as described in this Policy and our Terms of Use, including any updates thereto.

This policy DOES NOT apply to information you provide to or is collected by any third party. If you apply for a loan, you will receive an additional privacy policy applicable to the loan process at the time you apply.

If you have questions regarding this Policy please contact us via email us at [email protected], call us at 720-941-5037 or send mail correspondence to 1209 W. 10th Avenue, Denver, CO 80204.

2. Personal Information We Collect

Our Website and Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you, a particular consumer or device (collectively, “Personal Information”).

The Personal Information we collect is determined by the nature of your relationship with us and the context in which the Services are being accessed. For example, the Personal Information we collect will vary depending on whether you are a Program participant who has joined a particular program, a volunteer who has submitted a Volunteer Interest Form, a donor who has made a financial donation, an employee or employee candidate who has applied for a position, or a community stakeholder who has visited the Website or subscribed to our newsletter. Your relationship with us may be multidimensional. You may opt-out from further collection of your Personal Information at any time by ceasing to use the Website and Services.

Sources of Information We Collect Include

  • directly from you, for example, from forms you complete or orders you make on our Website and
  • indirectly, automatically from you via technology that automatically assesses your use of our Website and Services, for example, your device or equipment, browsing actions, and patterns.

Categories of Information We Collect Include

  • identifiers;
  • personally descriptive information;
  • location;
  • professional or employment-related information;
  • financial information;
  • content of correspondence;
  • internet and network activity information; and
  • commercial information.

Information We Collect Directly includes

  • your profile and identity information including your name, company name, postal address, phone numbers, email address, alias, account/application number, Driver License Number, State ID Number, EIN, SSN, TID number, and employee ID number;
  • details of financial transactions including credit card and bank account numbers;
  • financial records when you enroll in certain programs including personal and business tax returns, bank statements, and credit and consumer reports;
  • records and copies of your correspondence including the email address, fax number, or physical address from which the correspondence was sent;
  • other information you provide when completing forms, or responding to surveys;
  • commercial information including your company’s name, consumer and credit reports, Articles of Incorporation, Certificate of Good Standing, officer contact information, contact information for your financial and trade references, and purchasing history; and
  • employment history and information you enter when applying for a career with us; and
  • your signature.

This information is necessary for the legal relationship between you and us.

Additional Information We Collect Directly includes

  • demographic information including your date of birth;
  • protected class information including your gender, ethnicity, immigration status, race;
  • marital and family status, military veteran status, disability status;
  • voter registration status;
  • history of incarceration; and
  • inferences drawn from any of the above information.

This information is not necessary for the legal relationship between you and us.

Information We Collect Automatically Includes

  • real-time geographic location information about the location of your device;
  • your search queries on the Website including material and pages viewed;
  • name of your internet service provider;
  • information on the website you have visited us from;
  • information related to your social media account if you link the Website or our Services to your social media account;
  • the IP address assigned by your internet service provider;
  • requested files, amount of data transferred, downloads/files exported;
  • information on the pages of our Website that you visit, including date and time;
  • usage data including traffic data, number of bytes transferred, number of clicks per visit, logs,  and other communication;
  • device information including your internet connection, the device’s unique device identifier (UDID), MAC address, Internet Protocol (or IP) address,  sequence information, operating system, browser type and language, domain name system requests, mobile network information, and the device’s telephone number;
  • hypertext transfer protocol headers;
  • application client and server banners;
  • operating system fingerprinting data;
  • behavioral tracking, including information about your activities over time and across third-party websites, apps, or other online services; and
  • stored information files including metadata and other information associated with other files stored on your device such as, for example, photographs, audio and video clips, personal contacts, and address book information; and
  • inferences drawn from any of the above information.

This information is not necessary for the legal relationship between you and us.

We also keep track of how you use and interact with our Website and Services through the use of cookies and other tracking technologies as listed below. 

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and to gather other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
  • Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our Programs, Services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.
  • GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
  • Do Not Track Signals. Do Not Track (“DNT”) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with a service on the page. For details, including how to turn on DNT, see www.donottrack.us. Because there currently is not an industry or legal standard recognizing or honoring DNT signals, we do not respond to them at this time.
  • Social Media Widgets. The Website may contain links to our accounts on Facebook, Instagram, LinkedIn, Youtube, or other social media platforms. Clicking on any such link means that the respective platform may receive information indicating that you visited the platform from our Website. If you are currently logged in to your account on a particular platform, that platform may link this information to your account.
  • Keystrokes and Cursor Movement. We may use vendors to keep track of and/or collect your keystrokes (but not the specific information entered) and cursor movements when you visit our Website, but this information is anonymous and, at the time of collection, we do not directly associate or attempt to associate this information with you as an identifiable individual. We use this information solely for the purpose of improving our Website and our customers’ user experience (e.g., improving navigation, readability, etc.).
  • Analytics Software. We may use Google Analytics, Hotjar, Full Story, and other web analysis service. These services use cookies to track your use of our Website and Services and generate reports for us. Information is generated by the cookie regarding your use of our Website and Services and is usually transmitted to and stored on a server in the USA. The analytics service will use this information on our behalf to evaluate your use of our Website and Services, to compile reports on the activities within the Website, and to provide us with other services related to your use of our Services. Also, a pseudonymous usage profile may be created on you from the processed cookie information. You may prevent the collection by Google of the information generated by the Google cookie and Google’s processing of such information by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en. To prevent Hotjar from collecting your data, visit their website https://www.hotjar.com/privacy/do-not-track/.

Third-Party Information Collection

When you use our Website and Services, certain third parties may use automatic information collection technologies to collect Personal Information about you or your device. These third parties may include

  • your browser provider;
  • advertisers, ad networks, and ad servers;
  • analytics companies;
  • your mobile device manufacturer; and
  • your mobile service provider.

These third parties may also use tracking technologies to collect information about you when you use our Website and Services. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Further, where links to the websites of other companies are available, we have no influence as to their function or content. As a result, we provide no guarantee nor assume any liability for the collection practices, tracking technologies, or website function and content of any third party. Any Personal Information accessed, collected, or otherwise used through these third-party collection practices, tracking technologies, and websites is always and solely the responsibility of the respective company. If you have any questions about a website, an advertisement, or other targeted content provided by a third party, you should contact the responsible provider directly.

3. How We Use Your Personal Information

We use Personal Information that we collect about you or that you provide to us to

  • provide you with the Services and any other information, products, or services that you, an individual or entity acting on your behalf, or an individual or entity with whom or with which we have a business relationship request from us;
  • fulfill any other purpose for which you, an individual or entity acting on your behalf, or an individual or entity with whom or with which we have a business relationship provide the Personal Information;
  • notify you when updates to our Website and Services are available and of changes to any products or services we offer or provide;
  • provide you with information or services that you request from us or information about services that may be related to your request from us and for other marketing, promotions and advertising (including interest-based advertising) purposes;
  • be consistent with any way we may describe when you provide the information;
  • prevent fraud and enhance security;
  • respond to requests from law enforcement or other governmental authorities;
  • comply with any applicable law or legal obligation; and
  • consider consumers for employment or employ consumers and
  • for any other purpose with your consent.

The usage information we collect helps us to improve our Website and Services and to deliver a better and more personalized experience by enabling us to

  • estimate our audience size and usage patterns;
  • store information about your preferences;
  • speed up your searches; and
  • recognize you when you use the Website and Services.

4. With Whom and Why We Share Your Personal Information

We will only share your Personal Information with third parties as described herein, within the scope of applicable law, with the appropriate consent, and when obliged to do so due to mandatory legal regulations (e.g., disclosure to external bodies such as law enforcement authorities in the United States).

Entities with whom we may share your Personal Information include

  • contractors and service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them such as, but not limited to, for credit card processing and electronic funds transfers, electronic billing systems, business intelligence/financial analysis, file sharing systems, document management systems, customer relationship management, collaboration sites, accounting service providers, faxing, email, email management and security, Cloud storage, targeted advertising services, internet and network operations and security, information governance systems;
  • shipping companies;
  • consumer credit and background check providers;
  • a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred; and
  • our funders and donors, the public, government, or other entities when it is aggregated such that it becomes non-personal information that does not identify any individual, thus removing it from the restrictions of this Policy.

We share your Personal Information with these entities

  • to fulfill the purpose for which you provide it;
  • with your consent and at your direction;
  • for any other purpose disclosed by us when you provide the information;
  • to enforce or apply our Terms of Use;
  • to conduct or evaluate business transactions in our legitimate interests including (i) if we purchase other businesses or their assets, (ii) if we sell our business or assets, or (iii) if we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, and your Personal Information is among the implicated assets;
  • as aggregated non-personal statistical data to apply for grants and other funding and for required or discretionary disclosures related to the “community impact” of our Services;
  • as aggregated non-personal statistical data showing general usage patterns and statistics, interactions, and transactions with our Website and Services;
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others including by exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
  • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or other harm or in connection with an investigation of suspected or actual illegal activity including illegal activity perpetrated through the Website or Services or using our name;
  • if it is necessary to protect the vital interests (life, health or safety) of a person; and
  • to respond to legal requests,such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your Personal Information.

5. Choices About How We Use and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your Personal Information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Interest-Based Advertising. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (NAI) through their website, located at the time of this Policy at https://optout.networkadvertising.org/?c=1. You can opt out of receiving targeted ads from members of the Digital Advertising Alliance (DAI) through their website, located at the time of this Policy at https://youradchoices.com/#zone-preface1-wrapper. Additionally, you can set preferences for how Google advertises to you using the Google Ad Settings website or by using the Google Analytics Opt-out Browser add-on.
  • Email Marketing. We may periodically send you promotional materials or notifications related to our Programs or Services. If you want to stop receiving promotional materials, follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to our Website, Services, Terms of Use, or other policies or related to your Program application or account.
  • Google Analytics. You may prevent the collection by Google of the information generated by the Google cookie and Google’s processing of such information by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en.

6. Data Retention Period

We store your information as long as it is necessary for the processing purpose in question or in accordance with our data retention policy. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations.

In addition, we may retain your Personal Information if, in the event of legal disputes, we use the information as evidence.

7. Data Security

The security of your Personal Information is important to us. We make commercially reasonable efforts to secure and protect the privacy, accuracy, and reliability of your Personal Information and to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We do not offer online accounts for our Program participants or other consumers at this time. Internally, we have implemented security measures consistent with industry standards, including limiting employee access to your Personal Information and instituting two-factor authentication for accounts containing sensitive personal data. As no data security protocol is impenetrable, we cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information including your Personal Information is provided by you at your own risk.

8. Our Services Are Not For Children

Our Website and Services are not intended for children under 18 years of age. No one under the age of 18 may provide any information to, on, or through the Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information to, on, or through the Website or our Services or any of their features or provide any information about yourself to us, including, but not limited to, your name, address, telephone number, or email address. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

9. Special Notices

We only target and provide services to Colorado residents and Colorado-based businesses. However, we recognize the global nature of the internet may result in consumers who are not Colorado residents (“Non-residents”) accessing our Website and Services. We comply with the laws that are applicable to us. However, we strive to respect and protect the privacy of all persons who access our Website and Services, and we will work with you to resolve issues or concerns to the extent feasible. Further, upon request or notification, we will comply with the laws of your home country as it relates to your Personal Information.

  • Notice to California Residents. If you are a California resident (also referred to as a “Consumer”), the California Consumer Privacy Act (the “CCPA”) is not applicable to Rocky Mountain Microfinance Institute as a nonprofit.
  • Nevada Privacy Rights. If you are a Nevada residents who wishes to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
  • Notice to Residents of Non-U.S. Countries. If you are a resident of a country other than the United States of America, in addition to the disclosures made in this Policy, you may have other rights granted to you by your home country.

Transfer of Personal Data:

Our headquarters is in the United States. The Personal Information we or our service providers and contractors collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers and contractors have facilities around the globe, and certain Personal Information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers and contractors may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, transferring, processing, storing, and otherwise using your Personal Data outside of the country in which you reside.

10. Changes To Our Privacy Policy

We may modify this Policy from time to time. The most current version of this Policy will govern our use of your Personal Information and is located at https://www.rmmfi.org/privacy-policy. We will notify you of material changes to this Policy by posting a notice at the Website or by emailing you at an email address associated with you, if applicable, and provide an “at a glance” overview of any changes.