Privacy Policy

Equitable Food Initiative and its affiliates (“EFI,” “we,” “our,” and/or “us”) value the privacy of
individuals who use our platform (ECIP LAB), website (including https://ethicalcharterprogram.org/),
and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”)
explains how we collect, use, and disclose information from users of our Services (“you” or “your”).
By using our Services, you agree to the collection, use, disclosure, and procedures described in
this Privacy Policy. Beyond the Privacy Policy, your use of our Services is also subject to our
Terms of Service at ethicalcharterprogram.org/termsofservice.

Personal Information We Collect

We may collect a variety of personal information from or about you or your devices from various
sources, as described below.

A. Personal Information You Provide to Us.

Registration and Profile Information. When you sign up for an account to use our Services, we
ask you for your name, organization’s name, and email address.

Communications. If you contact us directly, including via support@ethicalcharterprogram.org, we
may receive additional information about you, such as your name, email address, phone number,
computer equipment and software you use, the contents of a message or attachments that you may
send to us, and other information you choose to provide. If you subscribe to our newsletter, then
we will collect certain information from you, such as your email address.

Payment Information. When you purchase a subscription for our Services, your payment-related
information, such as credit card or other financial information, is collected by our third-party payment
processor on our behalf.

Benchmarking Responses. When you participate in ECIP LAB, we ask you for your business
name, location, employee housing status, farm labor contractor status, and names of certain supply
chain partners such as contracted growers, suppliers, and buyers.

B. Personal Information We Collect When You Use Our Services

Location Information. When you use our Services, we have the ability to infer your general location information, for example by using your internet protocol (IP) address.

Device Information. We receive information about the device and software you use to access our
Services, including IP address, web browser type, operating system version].

Usage Information. To help us understand how you use our Services and to help us improve it, we
automatically receive information about your interactions with our Services, like the pages or other
content you view, the links that you click, and the dates and times of the major activities you
navigate.

Information from Cookies and Similar Technologies. We and our third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of
alphanumeric characters. We may use both session cookies and persistent cookies. A session
cookie disappears after you close your browser. A persistent cookie remains after you close your
browser and may be used by your browser on subsequent visits to our Services.
Please review your web browser’s “Help” file to learn how you may modify your cookie settings.
Please note that if you delete or choose not to accept cookies from the Service, you may not be
able to utilize the features of the Service to their fullest potential.

How We Use the Personal Information We Collect

We use the personal information we collect:
● To provide, maintain, improve, and enhance our Services;
● To understand and analyze how you use our Services and develop new products,
services, features, and functionality;
● To communicate with you, provide you with updates and other information relating to
our Services, provide information that you request, respond to comments and
questions, and otherwise provide customer support;
● For marketing and advertising purposes, such as developing and providing promotional
and advertising materials that may be relevant, valuable or otherwise of interest to you;
● To generate deidentified or aggregated data for any lawful purpose, including to
prepare engagement scores and supplier scores and to publish reports and
whitepapers;
● To facilitate transactions and payments;
● To find and prevent fraud and abuse, and respond to trust and safety issues that may
arise;
● For compliance purposes, including enforcing our Terms of Service or other legal
rights, or as may be required by applicable laws and regulations or requested by any
judicial process or governmental agency; and
● For other purposes for which we provide specific notice at the time the information is
collected.

How We Disclose the Personal Information We Collect

Partners and Affiliates. We may disclose any information we receive to our partners, corporate
affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

Vendors and Service Providers. We may disclose any information we receive to vendors and
service providers retained in connection with the provision of our Services.

Engagement Profile. We may disclose your Engagement Profile to the supply chain partners you
have identified within ECIP LAB. For Growers, your Engagement Profile is shared with Suppliers
who have identified you as a contracted producer. For Suppliers, your Engagement Profile is
shared with Buyers that are identified in ECIP LAB as your customers. De-identified and
aggregated benchmarking responses from all participating Growers in a Supplier’s supply chain will
be shared with the Supplier. De-identified and aggregated benchmarking responses from all
participating Suppliers in a Buyer’s supply chain will be shared with the Buyer.

Analytics Partners. We use analytics services such as Google Analytics to collect and process
certain analytics data. These services may also collect information about your use of other
websites, apps, and online resources You can learn more about Google’s practices by visiting
https://www.google.com/policies/privacy/partners/.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your
personal information if we believe doing so is required or appropriate to: (a) comply with law
enforcement requests and legal process, such as a court order or subpoena; (b) respond to your
requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt,
the disclosure of your personal information may occur if you post any objectionable content on or
through our Website.

Merger, Sale, or Other Asset Transfers. We may transfer or disclose your personal information to
service providers, advisors, potential transactional partners, or other third parties in connection with
the consideration, negotiation, or completion of a corporate transaction in which we are acquired by
or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.
Consent. We may also disclose your information with your permission.

Your Choices
Marketing Communications. You can unsubscribe from our promotional emails via the link
provided in the emails. Even if you opt out of receiving promotional messages from us, you will
continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we
do not respond to such signals.

Third Parties
Our Services may contain links to other websites, products, or services that we do not own or
operate. We are not responsible for the privacy practices of these third parties. Please be aware
that this Privacy Policy does not apply to your activities on these third-party services or any
information you disclose to these third parties. We encourage you to read their privacy policies
before providing any information to them.

Security
We make reasonable efforts to protect your information by using physical and electronic safeguards
designed to improve the security of the information we maintain. However, because no electronic
transmission or storage of information can be entirely secure, we can make no guarantees as to the
security or privacy of your information.

Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 13 years of
age, and no part of our Services is directed to children. If you learn that a child has provided us
with personal information in violation of this Privacy Policy, then you may alert us at
support@ethicalcharterprogram.org

International Visitors
Our Services are hosted in the United States and intended for visitors located within the Americas.
If you choose to use the Services from the European Union or other regions of the world with laws
governing data collection and use that may differ from U.S. law, then please note that you are
transferring your personal information outside of those regions to the U.S. for storage and
processing. We may also transfer your data from the U.S. to other countries or regions in
connection with storage and processing of data, fulfilling your requests, and operating the Services.
By providing any information, including personal information, on or to the Services, you consent to
such transfer, storage, and processing.

Update Your Information
You can update your account and profile information or close your account through your profile
settings.

Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be
effective when it is posted. If we materially change the ways in which we use or disclose personal
information previously collected from you through the Services, we will notify you through the
Services, by email, or other communication.

Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us
at support@ethicalcharterprogram.org or write to us at:
Equitable Food Initiative
200 Massachusetts Ave NW, Suite 700
Washington, DC 20001