Privacy Policy
Last updated: August 2021

Welcome! Thank you for visiting the Red Door Project (“Red Door”, “Red Door Project", "we”, “our” or “us”). This Privacy Policy explains how the Red Door Project collects, uses, and discloses information about you (“Personal Data”) when you access or use our Websites, mobile application(s), and other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

The Red Door Project takes compliance with all applicable data protection laws, including but not limited to the EU General Data Protection Regulation (GDPR) very seriously.  We adhere to the principles providing the greatest rights of privacy to every data subject.  Although headquartered in the United States, we have built our privacy program foundation on the more restrictive requirements embedded in the GDPR in Europe.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Services and tells You about Your privacy rights and how the law protects You.

  1. Definitions
  2. Types of Information Collected
  3. Uses of Information
  4. Sharing of Information
  5. Social Sharing Features
  6. Links
  7. Advertising and Analytics Services Provided by Others
  8. How long will we keep your Personal Data?
  9. Privacy Protections for Children Using the Internet
  10. Your Rights
  11. Your Responsibilities
  12. International Transfers of Information
  13. Data Security
  14. Contact Us

Definitions

For the purposes of this Privacy Policy:

  • “You” means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  • “Company” (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to the Red Door Project (“Red Door”), 3121 S MOODY AVE STE. 140 PORTLAND, OR  97239.
  • “Account” means a unique account created for You to access our Services or parts of our Service.
  • “Website” refers to Red Door Project's site, accessible from https://www.reddoorproject.org
  • Service Provider” (also known as the data processor) means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • “Third-party Social Media Service” refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • “Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • “Usage Data” refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • “Business” (also known as the data controller) refers to the Company as the legal entity that collects an individual's personal information and determines the purposes and means of the processing of the personal data, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of such personal data.
  • “Processing” means any operation or set of operations performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, hosting, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

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Types of Information Collected

Information You Voluntarily Give Us

When You access or use Red Doors’ Services, or transact business with Us, You may choose to provide Us with information about You, including:

  • For Registration: When you sign up for a Red Door Membership Account, we collect your name, email address and account credentials.
    Registration is not required to use Our website. If You are merely a visitor, we only collect limited information through the use of cookies. For information related to Our use of cookies please see the information provided below.
  • For Newsletter Signups: When you sign up for a Red Door mailing list (e.g., Story of the Week, Schools Program), we collect your name and email address. You can opt-out of receiving any communications by contacting Us at info@reddoorprojct.org or by clicking on Our “Unsubscribe” link in the communication that was sent to You.
  • For Billing: To process payments or donations, we use third-party services for payment processing (e.g., payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
  • For User-Generated Content: We offer you the ability to post content that other users can read. Anyone can read, collect and use any personal information included in or accompanying this content.
    We do not have to publish any of your content. If the law requires us to take down, remove or edit your personal information, we will comply to the required extent.
  • For Events, Blind Bias Surveys, Member Surveys, and Research: We gather information through voluntary questionnaires, event registration forms, surveys and feedback programs. We ask you for your consent to use this information when you participate in these programs and events.
  • During Contact With Red Door Staff: You may choose to provide Us with information directly when You contact us to request customer support, request information, apply for a job, participate in any interactive features of the Services, communicate with Us via third-party social media sites or otherwise communicate with Us.

Information Collected Automatically

When You access or use Red Doors’ Services, or transact business with Us, We may automatically collect de-identifiable information about You, including:

  • Log and Usage Information. We collect log information about Your use of the Services, including the type of browser and operating system You use, the domain and host from which You access the internet, access times, pages viewed, web browsing history, your IP address and other connection and usage data or information, and the page You visited before navigating to Our Services.
  • Device Information. We collect information about the computer or mobile device You use to access Our Services, including the hardware model, operating system and version, unique device identifiers and tokens, unique identifier headers, mobile network information, and other information that does not directly identify You.
  • Location Information. In accordance with Your device permissions, We may collect information about the precise location of Your device. You have the ability to stop the collection of precise location information at any time.
  • Information Collected by Cookies, Web Beacons, and Similar Tracking Technologies. We use different technologies to collect information, including cookies, web beacons, embedded scripts, e-tags/cache browsers, pixels and plug-ins. Cookies are small data files stored on Your hard drive or in device memory that help Us improve and keep secure Our Services and Your experience. Through the use of cookies, We may automatically collect information about Your online activity through Our Services, such as the web pages You visit, the links You click, and the searches You conduct on Our site.

Our Services use two types of cookies:

  • Session cookies which are deleted from Your computer when You leave the website and are used purely to help You navigate around the website.
  • Persistent cookies which remain on Your computer so that the Service can recognize You when You return.

In addition to other uses described in this Privacy Policy, We may use information collected through cookies in the following ways: (1) system administration and to prevent fraudulent activity; (2) to assess the performance of Our Services, including to improve the content offered through the Services; (3) to tell Us, for example, whether You have visited the online services before or if You are a new visitor and to help Us identify the features in which You may have the greatest interest; or (4) to deliver content, including advertisements relevant to Your interests, on Our online service and third-party sites based on how You interact with Our advertisements or content.

You have the right to decide whether or not We can place cookies on Your devices with the exception of cookies required for the performance of our Websites.

Information Collected from Other Sources

To the extent permitted by data protection laws, We may obtain information from other sources and combine that with information We collect directly from You. For example, We may collect information about You from third parties, including but not limited to, Google Analytics, social media plug-ins, identity verification services, mailing list providers, and publicly available sources. Additionally, if You create or log into Your account through a social media site, We may have access to certain information from that site, such as Your name, account information, and friends lists, in accordance with the authorization procedures determined by such social media site.

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Uses of Information

We use the information You have allowed Us to collect to deliver information about the products and services You request and customize Your experience with Us, to administer Your account, and to provide information based on Your interests. We may also use the information We collect to:

  • Manage Your account;
  • Send You technical notices, new content, updates, security alerts, and support and administrative messages and to respond to Your comments, questions, and customer service requests;
  • Analyze the success of Our Services;
  • Better understand the needs and interest of Our customers;
  • Manage the website’s interactive functionality;
  • Communicate with You about products, services, and offers provided by Red Door, and offer news and information We think will be of interest to You;
  • Monitor and analyze trends, usage, and activities in connection with Our Services;
  • Comply with Red Doors’ legal and regulatory obligations;
  • Detect, investigate, and prevent breaches of the Terms and Conditions, fraudulent transactions and other illegal activities, and protect the rights and property of Red Door and others;
  • Personalize and improve the Services; and
  • Carry out any other purpose described to You at the time the information was collected based on Your consent.

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Sharing of Information

We may share information about You as follows or as otherwise described in this Privacy Policy:

  • With approved 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, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
  • If We believe Your actions are inconsistent with Our user agreements or policies, or to protect the rights, property, and safety of Red Door or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of Our business by another company (applies to employee data only);
  • Between and among Red Door and Our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
  • With other users when You share personal data or otherwise interact in the public areas with other users. Such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile; and
  • With Your consent or at Your direction.

We require or vendors, consultants, and service providers that have access to Your Personal Data to maintain the confidentiality of Your Personal Data and to comply with the safeguards provided in this Privacy Policy and in compliance with Our Data Processing Agreements.  We also provide our vendors, consultants, and service providers with Our opt-in/opt- out lists so that communications sent on Red Doors’ behalf are only sent to users who have opted-in and who have not previously opted out.

Red Door will not sell, rent, or market Your information collected on the Services to non-affiliated third parties for their own purposes, including marketing, unless we have received Your consent. However, Red Door may disclose aggregated statistics about visitors using its Services, along with anonymous information collected from other sources. We may also share aggregated or de-identified information with third parties (such as advisors, promotional sponsors, and investors), which cannot reasonably be used to identify You, for various business purposes, including conducting general business analysis and developing website content and services.

Comments, emails, suggestions, or other communications sent by You to Us are deemed to be non-confidential (except with regard to personally identifying information included therein), and We are free to use or distribute them in any way without identifying You and without compensation to the author, sender, or any other party, pursuant to the terms provided for “User Content” and “Feedback” under our Terms and Conditions.

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Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you choose to share actions you take on Our Services with other media. Your use of such features enables the sharing of information with Your friends or the public, depending on the settings You establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

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The site may contain links to third-party Websites. Please recognize that We do not control these third-party Websites and this Privacy Policy will not apply to those Websites. You should consult each applicable privacy policy before using another linked website. Red Door is not responsible for the privacy practices or the content included on third-party Websites.

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Advertising and Analytics Services Provided by Others

Where permitted by data protection laws, We may allow others such as Google or Facebook to provide analytics services and serve advertisements on Our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about Your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. These companies collect and use this information under their own privacy policies. This information may be used by Red Door and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to Your interests on Our Services and other Websites, and better understand your online activity.

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How long will we keep your Personal Data?

We will keep Your Personal Data for the period permitted or required by law and where we need to do so in connection with legal action or an investigation involving Red Door. Otherwise, We will keep your Personal Data only as long as We have to so that We can continue to use the information for the reasons You agreed to.  You have the right to request that Your Personal Data be deleted once you no longer have a relationship with Red Door.  Red Door will honor Your request to have Your data deleted unless we have a legal, regulatory or contractual requirement to maintain it for a specific period of time.

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Privacy Protections for Children Using the Internet

Red Doors’ Services are intended for a general audience, and are not directed at children under the age of 13, or 16 where applicable. In cases where certain Red Door Services are intended for use by children under the age of 13 (or 16 where applicable), we will post appropriate notices and take steps as required by applicable law to safeguard children's data.

We do not knowingly gather personal information and do not knowingly sell the personal information of minors under 16 years old.

Red Door encourages minors to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet. Red Door encourages parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children.

If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at info@reddoorproject.org We will remove the data to the extent required by applicable laws.

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Your Rights

In certain circumstances, local data protection laws and certain other local laws gives You rights with respect to Your Personal Data. These rights differ by jurisdiction but may include:

  • The right to know what Personal Data Red Door collects, maintains, or shares about You and with whom Red Door shares Your Personal Data;
  • The right to request certain details about how Your Personal Data is shared with third parties for direct marketing purposes;
  • The right to request access to Your Personal Data;
  • The right to amend, update, or request correction or deletion of Your Personal Data;
  • The right to restrict Red Doors’ processing of Your Personal Data; and/or
  • The right to opt out of the sale or sharing of Your Personal Data.

Please note Red Door does not disclose Your Personal Data to third parties for the third parties’ direct marketing purposes. If You would like to exercise any of these rights, please contact Us at info@reddoorproject.org but note that We may retain certain information as required by law or for legitimate business purposes. We may also retain, when permissible by law, cached or archived copies of information about You as required by Our records retention practices.

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Your Responsibilities

You are solely responsible for the content, views, opinions and any other information You choose to share through Our Services. Any reactions to Your content, whether positive or negative, are not the responsibility of Red Door.  We do not influence, dictate or otherwise motivate the actions or reactions of any users and bear no responsibility or liability for the behaviour of others.

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International Transfers of Information

Red Door processes and stores information in the United States. If You use the Services from any other country, the various communications will necessarily result in the transfer of information across international boundaries to the United States. We have taken steps to comply with all applicable data protection laws, including implementation of European Union enhanced Standard Contractual Clauses (SCCs), to ensure that Your Personal Data receives an adequate level of protection in the jurisdictions in which it is processed. If You are in the European Economic Area (“EEA”), You have certain rights and protections under the law regarding the processing of Your Personal Data. If you are in the EEA, when We process Your Personal Data We will only do so in the following situations: (1) We need to use Your Personal Data to perform Our responsibilities under Our contract with you, (2) We have a legitimate interest in processing Your Personal Data (refer to our Lawful Basis for Processing Notification insert link here ), or (3) We have Your consent to do so. If You have a concern about Our processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where You reside.

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Data Security

We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any Personal Data We receive and process about You through the Services. We maintain reasonable security standards to protect the Personal Data that We process. Red Door cannot guarantee or warrant the security of the information You transmit to Us, and if You choose to use the Services and/or content, You do so at your own risk. There may be additional security risks if You provide Your Personal Data over a public or third-party network. Please keep in mind that the information disclosed by You on the website may be collected and used by visitors to the website.

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