Privacy Policy
1. Who we are
This Privacy Policy explains how GAIN Power, LLC ("GAIN Power") and Global GAIN ("Global GAIN") collect, use and share personal information through the websites, apps, tools, toolkits, trainings, newsletters and other services that link to this policy (the "Services"). The organization named in a Service's footer is the "Operator" and is responsible for the personal information collected through that Service. "We" and "us" mean the Operator.
The short version: we collect what we need to run our programs, we never sell your personal information, and we never share your mobile number or opt-in consent with third parties for their marketing.
2. Information we collect
Information you give us
- Contact and signup details: name, email, phone number, mailing address, ZIP code, organization and role, when you subscribe, register, RSVP or contact us.
- Account and profile information: login details, profile information, interests and preferences.
- Career and job information: résumés, work history, skills, references, job preferences, applications, and any voluntary demographic information you choose to share for equity reporting.
- Survey, training and program responses: answers, feedback, assessments and participation records.
- Payment and donation information: amount, date, billing name and address, and employer and occupation where we are required to ask. Card details are collected by our payment processors; we do not store full card numbers.
- AI tool inputs: text, files and prompts you enter into AI-powered features, and the outputs generated.
- Communications: messages you send us and your communication preferences.
Information collected automatically
- Device and usage data: IP address, browser and device type, pages viewed, links clicked, referring site, and approximate location derived from IP.
- Email and text engagement: whether messages are delivered, opened or clicked.
- Cookies and similar technologies (see section 7).
Information from others
- Employers or partners who refer candidates or post opportunities; event co-hosts; references you name; publicly available professional information; and service providers that help us verify or update contact details.
3. How we use information
- To provide, operate and improve the Services, including accounts, trainings, events, the Career Center and AI tools.
- To match candidates with opportunities and, with your direction, share applications with employers.
- To process donations, payments and receipts, and keep records required by law.
- To send emails and, if you opt in, text messages about news, trainings, events, opportunities and ways to support our work.
- To understand how the Services are used, measure program impact, and produce aggregate or de-identified reports.
- To keep the Services secure, prevent fraud and abuse, enforce our Terms, and comply with legal obligations.
4. How we share information
We do not sell your personal information. We do not share your mobile number, text-message opt-in or consent data with any third party or affiliate for their marketing or promotional purposes.
We share personal information only:
- Within the GAINiverse: between GAIN Power and Global GAIN where needed to run a joint program or Service you use. Global GAIN does not share its donor or participant information for partisan political activity.
- With employers and recruiters: your profile or application, when you apply for a role or choose to make your profile visible.
- With service providers who process data on our behalf under contract, such as email and SMS platforms, database and CRM tools, website hosting, payment processors, analytics, scheduling and AI providers. They may use it only to provide services to us.
- With event and training partners: your registration details, when you sign up for a co-hosted event and we tell you at signup.
- For legal reasons: to comply with law, legal process or reporting requirements; to protect rights, safety and property; or in connection with a merger, reorganization or transfer of a program to a successor organization, subject to this policy.
- With your consent or at your direction.
We may share aggregate or de-identified information that cannot reasonably identify you.
5. AI-powered features
When you use an AI feature, your inputs are sent to our AI service providers to generate a response. We use providers whose business terms do not allow them to train their models on your inputs. We may store inputs and outputs to provide the feature, improve the Service and prevent abuse. Do not enter sensitive information, such as health, financial or government ID details, or other people's personal information without their permission.
6. Email and text messages
You can unsubscribe from marketing email using the link in any message. You can stop text messages by replying STOP, or get help by replying HELP. Message frequency varies, and message and data rates may apply. Mobile carriers are not liable for delayed or undelivered messages. We keep a record of your consent and opt-out.
7. Cookies and analytics
We use cookies, pixels and similar tools to keep you logged in, remember preferences, understand site traffic (for example, with Google Analytics), and measure the reach of our outreach. You can accept or reject non-essential cookies in our banner, change browser settings, or install the Google Analytics opt-out add-on. We honor Global Privacy Control signals as an opt-out of non-essential tracking where required by law.
8. Sensitive information
Some information you share with us, such as political views, union membership, or voluntary demographic data, may be sensitive. We collect it only when you choose to provide it, use it only for the purpose you gave it, and do not share it with employers or third parties without your explicit consent.
9. Data retention
We keep personal information as long as your account is active or as needed to provide the Services, and then as needed for legal, tax, accounting and reporting purposes. Donation records are kept as required by law. When information is no longer needed, we delete or de-identify it.
10. Security
We use administrative, technical and physical safeguards appropriate to the information we hold, consistent with Massachusetts data security regulations (201 CMR 17.00). No system is completely secure. If a breach affects your personal information, we will notify you as required by law.
11. Your choices and rights
Wherever you live, you can ask us to access, correct, download or delete your personal information, or to stop using it for marketing. You can update most account information yourself. To make a request, email amy@gainpower.org. We will verify your request and respond within 30 days (or sooner where the law requires). We will not discriminate against you for exercising your rights. Depending on where you live, you may have additional rights under local law, including the right to appeal our decision or complain to a data protection authority.
12. International users
We are based in the United States and work with people around the world, including in Rwanda and the European Union. Your information may be processed in the United States and other countries whose laws may differ from yours. Where required, we rely on your consent, our legitimate interest in running our programs, or contracts with you as the legal basis for processing, and we use appropriate safeguards for international transfers.
13. Children
The Services are not directed to children under 13, and we do not knowingly collect their personal information. If you believe a child has given us information, contact us and we will delete it.
14. Third-party sites
Our Services may link to sites, payment pages and platforms we do not control. Their privacy policies govern how they handle your information.
15. Changes to this policy
We may update this policy. We will post the new version with a new effective date and, for material changes, notify you by email or on the Services.
16. Contact us
Privacy questions or requests: amy@gainpower.org
GAIN Power, LLC · mailing address available on request
Global GAIN · mailing address available on request