PRIVACY POLICY

The North American Christian Convention, dba Spire Network

Privacy Statement

This Privacy Statement describes how The North American Christian Convention dba Spire Network (“Spire” or “Spire Network” or “we”) collects, uses, shares, and safeguards personal information. It applies when you interact with us by visiting the Spire websites (“spire.network” and “spireconnect.network”), as well as any other website or mobile applications that references this Privacy Statement; participate in our events, promotions, offerings or partner activities; or interact or communicate with us as part of our marketing practices or community outreach. We offer a variety of products, services, mobile applications, and software offerings (collectively, the “Services”) that help leaders and the organizations they serve know and understand their members, prospective members, and communities; connect organizations and individuals to one another; and measure their impact as they help people on their journey towards spiritual growth. As part of providing the Services, we collect and receive information in a variety of ways, including information on our websites and applications, from our organizational customers and/or prospective customers, and from individuals that use the Services. 

For the purposes of this Privacy Statement, Spire is a controller (i.e., responsible party) of your personal information when we administer the Services directly on our own behalf. In certain situations, we also administer the Services on behalf of customers or other third parties. In those instances, Spire may act as a processor or service provider to such organizations, and you should review the privacy policy of such third parties with whom you are dealing directly, as they will be responsible for the handling of your personal information.

CATEGORIES OF INFORMATION WE COLLECT ABOUT YOU

The types of personal information we collect about you depends on how you interact with us. “Personal information” refers to information that identifies, relates to, describes, or can be associated with you. Depending on the Services you use, the following are the categories and specific types of personal information that we may collect:

Contact Information/Identifiers, including name, email address, postal address, phone number, username, social media information, business contact information, or other similar identifiers.

Demographic Information, including age, gender, race, ethnicity, and household information, some of which may include characteristics of protected classifications under state or federal law.

Device Information and Other Unique Identifiers, device identifier, internet protocol (IP) address, or similar unique identifiers.

Information About Your Use of the Services, including, in certain instances, requests for connections to certain organizations along with information regarding your specific concerns or needs, views and characteristics, such as indicators of your growth, assessment, and other survey responses, interests, views, opinions, perspectives, traits, or characteristics.

Internet or Other Network Activity, including browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.

Geolocation Data, including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.

Payment Information, including credit or debit card number, or other financial information. 

User Content, including your communications with us and any other content you provide (such as social media profiles, photographs, images, videos, survey responses, comments, testimonials, and other content).

Job Applicant Information, if you apply for or post a job posting or become an employee, we collect information necessary to process your application or post or to retain you as an employee. This may include, among other things, your social security number. Providing this information may be required for employment.

Sensitive Personal Information (where permitted and in accordance with applicable law). The provision of the sensitive personal information is voluntary. Of the information listed above, we collect your username, password. If you apply for a job with us, we may also collect your social security number. 

If you use some of our services, you may provide and, therefore, we may collect racial or ethnic origin, religious affiliation, sexual orientation, and/or health information which also qualify as sensitive personal information. We do not disclose sensitive personal information for purposes other than those which cannot be limited under California law. 

In certain instances, such as for application purposes, we will not be able to process your request for our Services without the requested personal information.

If you give us the personal information of another person, such as your professional references, we assume you have their permission to share their information with us.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information in the following ways, pursuant to applicable law:

Directly From You, when you purchase our Services, register for an account or create a profile, contact us, respond to a survey, apply for a job, sign up to receive emails, text messages, and/or postal mailings. 

Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our websites, use our mobile applications, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see “Cookies and Similar Tracking Technologies” section below.

From Our Third-Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us.

Other Sources, including data analytics providers, publicly available sources, employment or recruitment agencies, background check providers, or references. The information that we may obtain from certain data providers, third-party databases, and advertising networks is de-identified (i.e., it does not reasonably identify individual people).

USE AND PROCESSING OF YOUR PERSONAL INFORMATION

We use your personal information and sensitive personal information for the following business purposes (“Processing Purposes”) associated with our general business operations. We may collect your personal information:

Providing You Our Services

• If you register directly for an account with us or set up a profile on one of our applications, we collect your personal information to create, maintain, and otherwise manage your account and profile. 
• To process your payments and send notifications to you related to your account. 
• To enable you to access and use our websites and to provide requested Services.
• If you are a user who accesses and/or participates in any of our Services designed to facilitate personal growth.
• If you log in to our Services using credentials from a third party, for example Google or Facebook, we will receive information that you have made public via your privacy settings with that third party.

Communicating With You

• To communicate with you and to respond to your requests, questions, comments, and other inquiries.
• To send you information regarding your account, changes to our terms, conditions, and policies, and/or other administrative information.
• To connect you to resources and Spire partners with the appropriate notice and/or consent, where required. 

Marketing and Promotional Purposes

• To send marketing and promotional materials including information relating to our Services or those of our business partners.
• To understand what partner resources you use, if any, and to connect you to additional resources at your request.
• To offer you personalized advertisements, which you may be able to opt out of as explained in the “Your Choices” section. 

Analytics and Administration of Website

• To administer, maintain, evaluate, and improve our websites and Services, and to develop new products and services.
• To conduct research and analytics related to our websites and Services, including combining any or all of the information that we collect or obtain.

Core Business Functions

• To manage our business operations and perform our obligations and exercise our rights under any agreement that you or your organization has with us.
• For other purposes with your consent, or as otherwise permitted or required by applicable law.

Legal Obligations

• As we believe to be necessary or appropriate to: (a) comply with judicial proceedings, court orders or legal processes, or to respond to proper governmental request or investigation; (b) detect, prevent, or otherwise address fraud, security, or technical issues; (c) protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, procedures, and terms and conditions; (d) protect against harm to the rights, property, or safety of Spire Network, our users, or the public; and (e) protect the health and safety of users of our Services or other individuals.

Applicant 

• If you apply for a job with us, we use your personal information, including your social security number, to make decisions about recruitment and in anticipation of a contract of employment, provided this information is required for employment.

With regard to sensitive personal information, we only use your sensitive personal information to provide you with the requested products or Services and to administer your account.

DISCLOSURE OF YOUR INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Statement, we may disclose information in the following situations, as permitted by applicable law:

• Organizational Customers and Other Third Parties. We disclose information to certain organizations with whom we have a contract to provide Services. For example, if you are a user whose account is associated with an organization using our Services, your account information may be disclosed to other users or viewers who have joined that organization. Also, if your organization engaged us to administer an assessment, we may use your personal information to ask you to complete an assessment at your organization’s request. If you complete an assessment, we process the personal information you choose to provide to us to develop aggregated insights that do not contain any personal information about you. We may share these aggregated insights with your organization or other third parties. In addition, we may ask for your consent to disclose personal information from your assessment with your organization or other third parties. In addition and with your consent, if you are an individual who seeks out Services, we may disclose your personal information to other organizations or resources that might provide the types of services that you are requesting.
  • Certain Services are provided by third parties on Spire Network’s platform. By selecting or purchasing a third-party Service, you instruct Spire to disclose your name, email address, and other contact information with the applicable third party. If you do not desire for Spire to disclose your personal information to these third parties, do not select or purchase these third-party services. Further, if a third party has agreed to pay fees for a Service on your behalf, you instruct Spire to share your name and other contact information, and the Service you have purchased, with the applicable third party.
  • In addition, in certain instances, Spire may, but is not obligated to, disclose personal information to other organizations that can provide additional assistance to individuals, if it appears that immediate or crisis assistance may be necessary.
• Partners. We may disclose your personal information (including sensitive personal information) to our partners with your consent, where required. Partners include, but are not limited to, campaign partners, event referral partners, scholarship partners or donors, partners who refer you to Spire Network, and larger parent or network organizations (network partners) with whom you or your organization may be affiliated or have a direct relationship (for example, denominational or missional organizations), as well as certain other resources to provide additional services or assistance to you.
• Webinars and Events. We may disclose your personal information to our event referral partners when you register or attend a webinar or in-person event hosted or co-hosted by Spire Network. Event referral partners (also referred to as Spire Network partners) help us to organize our events and may have a pre-existing connection with you, for example, if they referred you directly or referred your affiliated organization to our event. We provide you with notice during event registration where your information may be disclosed with our network partners, for instance, to confirm your attendance at a webinar or event, to confirm sessions attended, or to confirm products purchased.
• Other Disclosures with Your Consent. We may ask for your consent to disclose your personal information to other recipients not described elsewhere in this Privacy Statement. For example, our Services include certain social media and other features that allow you to disclose information to other users, persons, and organizations when you use them. We provide you with notices while you use our Services that explain when one of the features you are using will result in the disclosure of your personal information to other users, persons, and organizations. We also provide settings that allow you to configure to whom your posts and content are available. When you use these types of features, you instruct us to disclose your information according to our notices and your settings.
• Service Providers. We disclose information to service providers as necessary for them to assist us with our business operations and provide services to us, subject to appropriate confidentiality and data protection agreements. Among other things, service providers assist us with website hosting, data storage, data analytics, helping with addressing security, fixing errors, processing payments, providing identity verification services, providing technical support, sending communications (including SMS/text messages), providing assessments, fulfilling user requests, and other activities related to the management of our business and services.
  • Certain Services may use third-party providers to send and receive SMS/text messages. These partners may process data as an independent controller in certain circumstances. One such third-party partner’s processing activities are described in its Privacy Notice, here.
• Compliance with Law and Protection of Legal Interests. We may disclose information for legal reasons as we believe to be necessary or appropriate to: (a) satisfy any applicable law, legal process, or proper governmental request; (b) enforce any agreement we may have entered into with you or your organization, including investigating any violations or asserting remedies; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) protect against harm (whether tangible or intangible) to the rights, property, or safety of Spire Network, our users, or the public as required or permitted by law; and (e) establish or exercise our rights, defend against a legal claim, and investigate, prevent, or take action regarding possible illegal activities or a violation of our policies. We may also disclose personal information to law enforcement or other regulatory authorities to protect the health and safety of users of our Services or other individuals or as we otherwise deem necessary.
• Business Transaction. We may disclose information to a potential or actual buyer in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), including any due diligence related to such a transaction.
• De-identified or Aggregate Information. We may aggregate and anonymize information you provide to us in such a way as that it will no longer be identifiable to you. This data may be used for statistical, analytic, and administrative purposes, including analyzing our website traffic and trends, tailoring our Services, or conducting product analysis. We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

Legal Basis of Processing

Provision of your personal information is both a contractual and statutory obligation. We process your information for the purposes described in this Privacy Statement, based on the following legal grounds:

• With Your Consent. In certain instances, we ask for your consent to process your personal information for specific purposes. Provision of your consent is voluntary, and you have the right to withdraw your consent at any time.
• When Pursuing Legitimate Interests. We process your personal information for our legitimate interests and those of third parties, while applying appropriate safeguards that protect your privacy, and as further described in this Privacy Statement.
• To Perform a Contract With You. We will process your personal information when processing of your personal information is necessary for the execution or performance of a contract with you.
• When We Have a Legal Obligation. We will process your personal information when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable government request, including law enforcement.

COOKIES AND SIMILAR TRACKING TECHNOLOGIES 

We use cookies and similar tracking technologies, including pixel tags or web beacons (collectively “cookies”), to collect certain information on our websites or through our Services. We also permit certain third parties to use cookies and similar tracking technologies to collect information about your use of our websites or Services. The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information (“Technical Data”); (b) information about when and how you access and use our websites or Services, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage (“Usage Data”); (c) information about the device you use to access the websites or Services, such as device type, device ID, and device/browser settings (“Device Information”); and (d) location of the device used to access the websites or Services derived from GPS or WiFi use (“Location Information”).

We differentiate between cookies that are essential for the technical features of the Services and optional analytics and advertising cookies.

Depending on your location and applicable laws, we may give you the option of adjusting your preferences with regard to the categories of cookies we use. When this option is available, you can configure your personal settings on our Cookies Banner under “Settings” or via other options that may be available on the relevant Service. If you use a different device to access the same Services, you may need to manage your settings for each separate device you use. 

Certain third parties provide ways to opt out of advertising cookies across multiple sites. You can learn more by visiting the sites of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://www.aboutads.info).

YOUR CHOICES

• Promotional Emails. You can opt out of receiving marketing or promotional emails by following the unsubscribe instructions contained in marketing or promotional emails you receive from us. If you decide not to receive marketing or promotional emails, we may still send you service or transactional-related communications, such as notices about your account.
• Promotional Text Messages. You can opt out of receiving text messages at any time by replying “STOP,” or following the unsubscribe instructions contained in the text message.
• Editing and Sharing Profile Information. Depending on the Services used, you may have the option to create and edit a profile which may be disclosed to networks, partners, or publicly through our directory. You can edit your profile information and review the settings in your profile to ensure you are connected to the appropriate networks and/or confirm whether you have the appropriate profile settings in place. 

Data Subject Rights

You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements under applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, the European Union, or United Kingdom). Specifically, you may have the following rights:

• Access: You have the right to request access to the personal information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the personal information has been or will be disclosed, the sources of the personal information, retention, and transfers of personal information. 
• Correction (Rectification): You have the right to request correction/rectification of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement. As noted above, you may also be able to correct your information in your account or profile. 
• Deletion (Right to be Forgotten): You have the right to request that we delete your personal information. As noted above, you may also be able to delete your information in your account or profile.
• Restriction of Processing: You have the right to request the restriction of processing of your personal information. Where applicable, the respective personal information will be marked accordingly and may only be processed by us for certain purposes.
• Data Portability: Under certain circumstances, you have the right to receive the personal information about you that you have provided to us, in a structured, commonly used, and machine-readable format.
• Objection to Processing: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information by us. Where such right applies, we will no longer process the relevant personal information for such purposes.
• Opt Out of the Sale or Sharing of Personal Information: You have the right to prohibit/opt out of the “sale” or “share” of personal information. However, we have not “sold” or “shared” your personal information in the past 12 months.
• Right of Non-Discrimination/Retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Statement, nor do we retaliate against individuals who exercise these rights.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. 

Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

To submit a request to exercise any such rights (if they apply to you), please use our Data Subject Rights request form. You may also send us an email at info@spire.network

Depending on where you are located, you may have the right to lodge a complaint with the relevant supervisory authority.

HOW WE PROTECT YOUR INFORMATION

We have implemented measures intended to protect your personal information from unauthorized access, use, or disclosure. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. In the event that we are required by law to inform you of a breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

The safety and security of your information also depends on you. You are responsible for keeping your account information and password secure and you should notify us of any unauthorized use of your account promptly.

HOW LONG WE RETAIN YOUR INFORMATION

We retain information about you and your use of our Services for as long as is needed to fulfill our legitimate business purposes outlined in this Privacy Statement. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the personal information is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations. 

TRANSFERS OF INFORMATION TO OTHER COUNTRIES 

We are based in the United States. If you are located outside of the United States, you should be aware that your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States, and the laws may be less stringent than the laws in your country. Where required by applicable law, we will provide appropriate protections for personal information transferred to the United States, including by implementing appropriate contractual controls.

CHILDREN’S PRIVACY 

Our Services are not intended for persons under 13 years of age. We do not knowingly collect or maintain personal information from persons under 13 years of age. If we learn that we have collected personal information from persons under 13 through our Services, we will take appropriate steps to delete this information. 

THIRD PARTIES AND LINKS TO OTHER WEBSITES AND SERVICES

Our websites and Services may contain links to websites, content, or services owned or operated by third parties. Please note, we have no control over the privacy practices of websites or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed. 

Some of our websites and Services may include plugins, widgets, or other features offered by social media platforms and networks, such as Facebook and Instagram and X (formerly known as Twitter). If you choose to use these features, certain information may be disclosed to or collected by those social media companies. For more information about the privacy practices of those social media companies, including what information may be collected and disclosed, please review the privacy policies and terms of the applicable company. 

Our websites and Services may also include functionalities and/or services provided by third parties. For example, some of our websites utilize the YouTube API Services to provide video content. When you interact with the YouTube functionality available through one of our websites, you will be subject to the YouTube Terms of Service (https://www.youtube.com/t/terms) and Privacy Policy (http://www.google.com/policies/privacy). We also use Google Places API on some of our websites to make it easier for our users to perform place-related searches and to fill in address details automatically. The data collected by this feature is subject to Google’s Terms of Service, located at: https://www.google.com/intl/en/help/terms_maps.html; and Google’s Privacy Policy, located at: https://www.google.com/policies/privacy/. 

DO NOT TRACK SIGNAL

Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. Not all browsers offer a DNT option and there is currently no industry consensus for how to recognize or respond to a DNT signal. For these reasons, Spire Network does not currently respond to DNT signals.

CHANGES TO THIS PRIVACY STATEMENT 

We may update this Privacy Statement from time to time to reflect changes to our practices, technology, legal requirements, and other factors. When changes are made to this Privacy Statement, they will become effective immediately upon posting. You can check the date at the bottom of this page to see when this Privacy Statement was last revised. We encourage you to review this Privacy Statement periodically for the latest information on our information processing practices.

To the extent that our Privacy Statement changes in a material way, the Privacy Statement that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent (express or implied) to the new Privacy Statement where and as required by applicable law.

CONTACT INFORMATION

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information. 

Data Protection Officer 
Spire Network
PO Box 1197 
Longmont, CO 80502 
info@spire.network 

Last Updated 9/15/2023