Privacy Policy

Privacy Policy

Effective Date: January 2026

1. Introduction

Code for Science & Society (CSS) ("we," "us," or "our") is a nonprofit organization that serves as the legal and fiduciary home for its fiscally sponsored projects under a Model A (Comprehensive) Fiscal Sponsorship structure. Under Model A, Sponsored Projects become a fully integrated part of Code for Science & Society, and we assume full legal, financial, and governance responsibility for their activities.

We are committed to protecting the privacy and confidentiality of personally identifiable information entrusted to us by donors, grantees, employees, contractors, volunteers, Fiscally Sponsored Project leaders, and other stakeholders.

2. Scope

This Policy applies to personally identifiable information (PII) collected in connection with

CSS’s Model A fiscal sponsorship program and related administrative operations, including:

• Fiscally Sponsored Projects operating exclusively under Model A sponsorship with CSS
• Project orientation, onboarding, and ongoing compliance activities
• Accounts payable, payroll, benefits administration, and human resources
• Grantmaking, fundraising, donations, and donor communications
• Advisory Committee governance and Project Leader oversight
• Employment, contracting, and volunteer engagement
• CSS-managed websites, systems, and electronic communications

This Policy does not apply to third-party websites or services that may be linked from our website.

3. Information We Collect

We collect PII as necessary to fulfill CSS’s legal and operational responsibilities as the fiscal sponsor and grantee of record under Model A sponsorship.

a. Donors and Funders

• Name, address, email, phone number
• Donation amount, date, and payment method
• Employer and matching gift information
• Information found in grant agreements, reports, and compliance documentation
• Communication preferences

b. Fiscally Sponsored Project Leads, Advisory Committee Members, and Project
Personnel

• Contact and demographic information (including required email and mailing addresses)
• Orientation, onboarding, and compliance records
• Financial, payroll, and reimbursement documentation
• Grant proposals, budgets, reports, and coding information
• Employment, contractor, and insurance records
  

c. Employees, Independent Contractors, and Volunteers

• Contact and demographic information
• Employment eligibility and payroll records
• Contractor agreements, W-9/W-8BEN forms, and insurance documentation
• Volunteer indemnification and release forms
• Information from banking/financial forms and transactions

d. Website and Electronic Communications Users

• IP address and browser information
• Pages visited and usage data
• Cookies or similar tracking technologies
• Electronic signatures and communication records

4. How We Use Information

We may use PII to:

• Operate and administer Sponsored Projects as internal programs of the organization
• Process donations, grants, and program expenditures
• Maintain financial, legal, employment, and regulatory compliance
• Provide oversight, risk management, and internal controls for Sponsored Projects
• Communicate with donors, funders, project staff, and other stakeholders
  Manage employment, contracting, and volunteer relationships
  Improve our services, and website

5. Legal Basis for Processing (if applicable)

Where required by law, we process PII based on:

• Consent
• Performance of a contract or fiscal sponsorship agreement
• Compliance with legal obligations
• Legitimate nonprofit and operational interests

6. Information Sharing and Disclosure

We do not sell personal information. Consistent with CSS’s responsibilities as the legal sponsor
and employer of record under Model A fiscal sponsorship, we may share information as
necessary with:

• ​Fiscally Sponsored Project Leaders, Advisory Committee members, employees, and
  contractors acting on behalf of CSS
• Payment processors, payroll providers, benefits administrators, insurers, auditors, and IT
  vendors
• Funders and government agencies, as required by grant terms or law
• Legal counsel and professional advisors retained by CSS

ensure compliance, and protect CSS’s tax-exempt status. All recipients are required to protect
information and use it only for authorized purposes.

7. Data Retention

We retain personal information only for as long as necessary to fulfill operational, legal,
accounting, and reporting requirements. Retention periods may vary depending on the type of
information and applicable laws.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal
information against unauthorized access, disclosure, alteration, or destruction. Despite these
measures, no system can be guaranteed to be 100% secure.

9. Individual Rights

Because Fiscally Sponsored Projects operate as internal programs of CSS under Model A
sponsorship, CSS is the data controller for personal information processed in connection with
project activities. Depending on applicable law, individuals may have the right to:

• ​Access their personal information held by CSS
• Request correction of inaccurate or incomplete information
• Request deletion or restriction of processing, subject to legal and record-retention
  requirements
• Withdraw consent where processing is based on consent
  

Requests must be submitted to CSS using the contact information below and may be subject to
verification.

10. Children’s Privacy

We do not knowingly collect personal information from children under the age of 13 without
parental consent. If we become aware that such information has been collected, we will take
appropriate steps to delete it.

11. International Data Transfers

If personal information is transferred outside the United States, we take reasonable steps to
ensure appropriate safeguards are in place.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on our website
with a revised effective date.

13. Contact Information

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Code for Science & Society
3934 SE Hawthorne Blvd.
#247
Portland, OR 97214
[email protected]
(503) 383-1281