Privacy Policy
Version 1
RAÍCES SIN FRONTERAS
Privacy Policy
Effective Date: 10/31/2026
Last Updated: 10/31/2026
Privacy Contact: mel@caficolorado.org
1. Introduction
Raíces Sin Fronteras ("Raíces," "we," "us," or "our") respects the privacy of participants, families, volunteers, instructors, facilitators, and website visitors.
This Privacy Policy explains how personal information is collected, used, disclosed, protected, retained, and managed through the Raíces website, registration platform, and Programs.
Raíces is an unincorporated community organization fiscally sponsored by Tri-County Health Network, doing business as Thrive Community Health Network ("Thrive").
Raíces and Thrive may have different responsibilities concerning particular information, depending on their actual operations and agreements.
2. Information Collected
Depending on the service or Program, we may collect:
Registration Information
Participant names;
Email addresses;
Telephone numbers, when provided as contact information;
Selected workshops and sessions;
Registration and attendance statuses;
Preferred language;
Age eligibility category;
Parent or guardian contact information.
Minor Participant Information
Minor's name;
Applicable child or youth category;
Workshop registration details;
Parent or guardian information;
Required consent and waiver records.
Exact dates of birth, identification documents, and medical histories are not ordinarily required for routine workshop registration.
Waivers and Consent Records
Signed documents;
Document versions;
Signature dates and times;
Associated participant and Program identifiers;
Guardian representations;
Electronic acknowledgment records;
Technical audit information reasonably necessary to verify acceptance.
Accommodation Requests
Contact information;
Requested accommodation;
Relevant functional needs voluntarily provided;
Communications and actions concerning the request.
Communications
Administrative emails;
Email delivery status;
Assistance requests;
Registration inquiries;
Relevant communication preferences.
Evaluations and Feedback
Workshop evaluations;
Satisfaction responses;
Suggestions;
Other voluntarily submitted feedback.
Technical Information
IP addresses;
Browser and device information;
Session information;
Access and security logs;
System errors;
Records needed to investigate unauthorized activity.
3. How Information Is Used
Information may be used to:
Process registrations.
Determine Program eligibility.
Manage capacity and waitlists.
Confirm attendance.
Administer waivers and consent.
Send administrative email notifications.
Respond to assistance and accommodation requests.
Support authorized Program delivery.
Respond to emergencies and safety incidents.
Investigate legitimate misconduct or security concerns.
Maintain system security.
Support grant and fiscal reporting.
Meet applicable legal and contractual obligations.
Improve Programs and registration processes.
Information shall not be used for materially unrelated purposes without an appropriate legal basis or required consent.
4. Information Concerning Minors
The registration platform is intended primarily for use by adults registering themselves or minors under their legal authority.
A parent or legally authorized guardian must register a minor.
Raíces seeks to minimize personal information collected concerning children and youth.
Children should not independently submit personal information through the registration platform without appropriate authorization.
We do not sell children's personal information or knowingly use it for behavioral advertising.
Parents and guardians may request access, correction, or deletion of information concerning minors under their legal authority, subject to verification and applicable legal obligations.
5. Fiscal Sponsor Information Sharing
Thrive may receive information reasonably necessary for its authorized fiscal sponsorship, financial oversight, grant reporting, insurance administration, legal compliance, or other agreed responsibilities.
Fiscal sponsorship does not automatically authorize unrestricted access to all participant records.
Raíces and Thrive shall determine their respective responsibilities for information access, confidentiality, retention, security, and incident response through appropriate agreements and operational procedures.
Where Thrive independently collects or controls information, its applicable privacy policies may also apply.
6. Volunteers, Instructors, and Facilitators
Authorized personnel may access only the information reasonably necessary to perform their assigned duties.
Examples may include attendance rosters, participant names, relevant safety instructions, or necessary accommodation arrangements.
Personnel shall not use participant information for unrelated personal, commercial, or promotional purposes.
Access to sensitive records, including accommodation details, incident reports, and guardianship disputes, shall be restricted to authorized individuals.
7. Technology Providers and Contractors
Raíces may use authorized developers, hosting providers, database administrators, email delivery services, document-processing services, and other technical contractors.
Such providers may process information only as authorized and subject to applicable contractual and legal requirements.
Providers are not authorized to sell participant information or use it for unrelated independent marketing.
Raíces will seek appropriate safeguards governing access, confidentiality, security, incident reporting, and return or deletion of information.
8. Email Communications
Raíces uses email for administrative communications, including registration confirmations, schedule changes, reminders, waitlist notices, waiver reminders, cancellations, and related Program information.
Administrative emails may be necessary to manage a registration.
Where promotional email communications are offered, Raíces will comply with applicable notice, consent, and unsubscribe requirements.
Participants are encouraged to keep their contact information current.
9. Accessibility and Accommodation Information
Accommodation information will be handled with particular care.
Raíces generally does not require a medical diagnosis merely to receive an accommodation request.
Information will be shared only with individuals who reasonably need it to evaluate or implement the accommodation or fulfill a legal obligation.
Raíces will avoid unnecessary disclosure of sensitive information to instructors, volunteers, or other participants.
10. Photography and Media
Raíces may seek authorization to use photographs, recordings, or other identifiable media for promotional or educational purposes.
Optional promotional use requires appropriate authorization.
For minors, legally required parent or guardian consent will be obtained.
Consent may be withdrawn prospectively as permitted by applicable law and the terms of a valid authorization.
Raíces cannot guarantee removal of materials already independently distributed by third parties.
11. Cookies and Technical Services
The website may use essential cookies, session identifiers, and similar technologies to support registration, language preferences, security, and platform operation.
If nonessential analytics or tracking technologies are introduced, Raíces will update its disclosures and obtain any legally required consent.
12. Information Security
Raíces seeks to implement reasonable safeguards appropriate to the information it handles.
Measures may include:
Encrypted connections;
Role-based access controls;
Restricted administrative permissions;
Confidential registration links;
Security logging;
Software maintenance;
Backup procedures;
Access reviews;
Incident response processes.
No electronic system can be guaranteed completely secure.
Raíces will evaluate suspected incidents and provide notifications when required by law.
13. Registration Link Security
Participants may receive unique links to access or manage registrations without creating an account.
These links should be kept confidential.
Raíces may revoke or replace a link when reasonably necessary for security.
Users should report suspected unauthorized access promptly.
14. Data Retention
Raíces retains personal information only as long as reasonably necessary for legitimate Program operations, legal compliance, grant obligations, insurance purposes, dispute resolution, or other authorized purposes.
Different record categories may have different retention periods.
Waiver and consent records, records involving minors, incident reports, and records subject to a legal hold may require extended retention.
When retention is no longer justified, information will be deleted, de-identified, or securely archived under an approved retention schedule.
15. Privacy Requests
Individuals may contact Raíces to request access to, correction of, or deletion of personal information.
Requests will be evaluated under applicable law.
Reasonable identity or authority verification may be required.
Raíces may retain information when required or permitted by law, including for legal obligations, preservation duties, or legitimate dispute resolution.
Where applicable law grants additional rights, appeals, or opt-out mechanisms, Raíces will provide them.
16. Safety and Legal Disclosures
Information may be disclosed when reasonably necessary and lawful to:
Respond to emergencies;
Comply with legal process;
Report suspected child abuse or neglect;
Investigate serious misconduct;
Protect individuals from imminent harm;
Address a legitimate security incident;
Comply with other applicable legal obligations.
Disclosure will be limited as appropriate to the circumstances and governing law.
17. Complaints and Nonretaliation
Individuals may raise privacy concerns without retaliation.
Reports will be reviewed in good faith.
Raíces will protect confidentiality to the extent reasonably possible, recognizing that some disclosures may be necessary for investigation or legal compliance.
18. Grant Reporting
Raíces may provide reports to Thrive, grantors, and authorized oversight bodies.
Aggregated or de-identified information will be used where practicable.
Personally identifiable information will be shared only when appropriately authorized or otherwise lawful and necessary.
19. External Websites
The website may link to third-party websites and services.
Independent third parties may maintain separate privacy policies.
Raíces is not responsible for independently operated third-party services except to the extent responsibility arises from applicable law or Raíces' own conduct.
20. Changes in Fiscal Sponsorship
If Raíces changes fiscal sponsors or ceases operations, participant information will be handled according to applicable law, contractual obligations, retention requirements, and appropriate participant notices.
Fiscal sponsorship changes do not automatically authorize unrestricted transfer of participant information.
21. Thrive Privacy Policy
Thrive maintains separate privacy policies governing information it collects or processes in connection with its own operations.
Participants may review those policies at:
Raíces' Privacy Policy governs the information practices described here and does not automatically incorporate all of Thrive's separate policies.
22. Changes to This Policy
Raíces may update this Privacy Policy as its practices or legal obligations change.
Material changes will be communicated where required.
Any new processing activity requiring consent will be subject to the applicable consent requirements.
23. Contact
Raíces Sin Fronteras
mel@caficolorado.org
Fiscal Sponsor:
Tri-County Health Network
Doing business as Thrive Community Health Network
238 East Colorado Avenue, Suite 8
Telluride, Colorado 81435
END OF PRIVACY POLICY