Last Modified: January 10, 2022
Update Log: N/A
Collection and use of personal information
If you make a donation, either online or otherwise, we will request certain personally identifiable information about you (such as your name, address, telephone number, email address, and credit card information) (“Personal Information”). We use this information to process your donation and communicate with you about it. We also receive personally identifiable information from partner organizations when you make a donation through them and elect to share your information with us. We also use publicly available information about our donors from third-party sources to personalize communications with donors and improve donor retention. We check in with donors throughout the year about whether you are interested in donating again. In addition, we may use this information to keep you updated about our work if you explicitly indicate that you would like us to do so. You can choose to stop receiving check-in and update information by following the unsubscribe instructions included in the materials or by contacting us at email@example.com. We may use such information to market Company or evaluate the success of our marketing and promotional efforts, analyze website usage, and improve our website's content, layout, and services. If you would like to opt out of sharing your information with our service providers for Company’s marketing purposes, please send an email to this address [email] and indicate your preferences.
Company may employ vendors to assist us with such functions as hosting our donor information database, sending email, modeling our data, marketing and promoting Company to donors and new audiences, and processing online and mail donations and credit card payments. In addition, Company consults advisors in making organizational decisions and developing long-term plans. These companies and advisors have access to donor personally identifiable information as needed to perform their functions. Company requires that they keep such information confidential and that they not use such information for purposes other than the functions they are assisting us with. (See Security section below.)
We do not sell, rent, or give donor personally identifiable information to any other party not under the employ of, or in a direct advisory or vendorship role to, Company, with one exception: if you give us permission to share your name, contact information, and details of your donation with one or more of our recommended charities. We will not share your information with these organizations unless you explicitly give us permission to do so.
We may disclose to third parties aggregate statistics regarding donations, but these statistics do not include any personally identifying information. The information given includes total number of donors and total amount of donations for specific periods of time.
Other information submitted
Through our site or otherwise, you may decide to submit personally identifiable information (such as your name, postal address, and email address) for purposes other than donating (such as receiving an email newsletter or further information as to a particular topic, or commenting on our blog). We collect and store this information and use it for the purposes for which you submitted it.
We may use such information for our marketing and promotional efforts, to analyze website usage, and to improve our website's content, layout, and services. We do not share this information with any third parties except those that assist us with certain functions, as described above. Company requires that these third parties keep such information confidential and that they not use such information for purposes other than the functions they are assisting us with. (See Security section below.) If you’d like to opt out of receiving newsletters or other communications from us, you can follow the unsubscribe instructions in the materials or contact us at firstname.lastname@example.org.
Automatic Information Collection and Tracking
When you access and use the Website, it may use technology to automatically collect:
If you do not want Company to collect this information, do not access the Website. Company also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services.
As with many other websites and mobile applications, the web servers used to operate the Services collect certain data pertaining to you and the equipment and communication methods that you use to access the internet and the Website. Without combining this data with other sources of information, the servers do not readily identify you. They do, however, reveal such things as the Internet protocol (“IP”) address assigned to your computer, pages you accessed on the Website or immediately prior to visiting the Website, and the length of time you accessed the Website. This information is collected to, among other things, facilitate Website operation and system administration, to generate aggregate, non-identifiable statistical information, and to improve content and content delivery with regard to the Website and the materials, products, and services that Company makes available on and through the Website.
You may send someone else a communication from the Website, such as sending an invitation to a friend or communicating with third parties. If so, the information you provide (names, email addresses, mobile number, etc.) is used to facilitate the communication and is not used by Company for any other marketing purpose unless Company obtains consent from that person or Company explicitly says otherwise. Please be aware that when you use any send-to-a-friend functionality on the Website, your email address, mobile number, name or username and message may be included in the communication sent to your addressee(s). Additionally, any communication with more than one friend will be sent as a multi-media group message and may include your Personal Information or the Personal Information of each third party. If you provide Company with the information of another person, you must have their consent to do so.
Please be advised that we may disclose your personal information, as required by law, to the government or to third parties pursuant to law enforcement inquiries, court orders, subpoenas, and similar lawful demands or legal processes. In addition, we may disclose your personal information with or without a formal subpoena if we believe in good faith that such disclosure is necessary or appropriate (a) in connection with any activity that violates the law, (b) in the event of a legal dispute, (c) to prevent or stop activity we believe may pose a risk of being illegal or unethical or that may expose us to liability, or (d) to protect the safety of the public or any person, or the rights of Company. In addition, we may sell, assign, transfer, or otherwise share some or all of our assets, including your personal information, in connection with a business transfer such as a merger, acquisition, sale of assets, or reorganization, or in the event of bankruptcy.
Some features of our website (such as commenting on our blog) may allow you to elect to share information publicly, in which case we would make such information available in accordance with the options you elect.
We require that the vendors we work with to process your online donation payments use industry-standard encryption and security protocols, and that all vendors processing check and credit card transactions received on our behalf meet all industry standards, certify their compliance with the Payment Card Industry Data Security Standard (PCI DSS), and are audited to meet the Statement on Auditing Standard 70 (SAS 70). We follow commercially reasonable administrative, technical, and physical safeguards to protect personal information against accidental or unlawful destruction or loss, or unauthorized disclosure, access, or use. The personal information that you provide is stored in a secure location and accessible only by designated employees trained in the proper handling of personal information, or by vendors assisting with certain functions. We employ industry-standard techniques such as firewalls, encryption, intrusion detection, and site monitoring to protect your personal information from unauthorized access by users inside and outside the organization. You should be aware, however, that "perfect security" does not exist on the Internet or in any method of storage; third parties may unlawfully intercept or access transmissions or stored information. If we learn of a security breach involving your personal information, we will inform you of the breach in accordance with applicable law.
Updating your information
We work to process and maintain accurately the information that you share with us. If you have donated to us or shared personal information with us and would like to correct or update your personal information or adjust your mail preferences, you can do so by contacting us at email@example.com. We will respond to your request in accordance with applicable law. We provide a link to unsubscribe from each of our mailing lists in each email from that list.
If you would like to opt out of sharing your information with our service providers for Company’s marketing purposes, please send an email to firstname.lastname@example.org and indicate your preferences. If you’d like to opt out of receiving newsletters or other communications from us, you can follow the unsubscribe instructions in the materials or contact us at email@example.com.
Website visitor information
You can browse the Company sites without telling us who you are or revealing any personally identifiable information about yourself. The information we gather during browsing comes from three sources. First, standard server logs collect information such as the IP (Internet Protocol) address, domain name, browser type, operating system, the site that referred you to us, the files you downloaded, the pages you visited, and the dates/times of those visits. Second, if you have come into the site from one of our newsletters, emails, or other outreach communications, or from a site that has requested a special link to us, we may track the information provided in that link (e.g., the name of the newsletter, what marketing campaign it’s associated with), in order to help us match referring sites to donations made. Third, some information is gathered by cookies.
Cookies and similar technologies
Company uses “cookies” (small text files stored on your computer) to help track and customize your access and use of the Services. Cookies store and retain information that helps Company recognize you when you return to the Services following a previous visit. Cookies may also store any login or ID assigned to you by Company and the associated password, which information would be stored in encrypted form. Most popular internet browser packages allow you to configure the browser so as to not accept cookies if you so choose. However, setting your browser to reject cookies may prevent you from taking full advantage of the Services and the materials, products, and other services that Company makes available on or through the Services.
Company may also use the following:
Flash Cookies. Certain features of the Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Company’s Use and Disclosure of your Information below.
Web Beacons. Pages of the Services and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company to, for example, count Users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Note to parents and children
Our site is not intended for use by children under the age of 16. Company welcomes children to learn more about our organization and about issues presented on the Company sites, and we are particularly respectful of the privacy of our young users. We encourage parents to monitor their children's use of the Internet and to help us protect their privacy by instructing them never to provide personally identifiable information on this site or any other without permission. We will never attempt to extract unnecessary information from our users, regardless of age. Consistent with the Children's Online Privacy Protection Act of 1998 ("COPPA") and the European Union General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679), we will never knowingly request personally identifiable information from anyone under the age of 16 without prior verifiable parental consent. If we become aware that a child under 16 has provided us with such information without consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that a child under 16 has provided such information to us, they should contact us at firstname.lastname@example.org.
Your California privacy rights
If you are a California resident, California law may provide you with additional rights regarding Company’s use of your Personal Information under the California Consumer Privacy Act (“CCPA”). Depending on the circumstances and which Website you use, Company has disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months: identifiers; protected characteristics; commercial information; geolocation data; internet or other electronic network activity information; financial, medical, or health insurance information; audio, electronic, visual, thermal, olfactory, or similar information; professional information; education information; and inferences drawn from any of the aforementioned information categories. For more details about the Personal Information Company has collected over the last 12 months, please see the Donor Information section above. Company collects this information for, among other things, the business and commercial purposes described in the Collection and Use of Personal Information section above. Company shares this information with, among others, the categories of third parties described in Collection and Use of Personal Information section below.
Company does not “Sell” (as such term is defined in the CCPA) the Personal Information it collects. The CCPA considers some transfers of Personal Information to third parties in exchange for value as a “Sale,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with third-party businesses to further their own commercial purposes such as generating profiles about individuals. Please note that Company can still share Personal Information with third parties if those transfers aren’t “sales,” such as with Company’s Service Providers (as defined in the CCPA). Additionally, Company may use third-party cookies for advertising purposes as further described above.
Subject to certain limitations, the CCPA permits Users of the Website that are California residents to (i) request more information regarding Company’s collection of specific categories or pieces of information (including how Company uses and discloses the information), (ii) request that Company delete your Personal Information (iii) request to opt out of any “sales” that may be occurring, and (iv) not be discriminated against for exercising any of these rights.
California residents may make such a request pursuant to their rights under the CCPA by sending an email to email@example.com. Company will verify your request using the information associated with your account, including email address. Government identification may be required. California residents may also designate an authorized agent to exercise these rights on their behalf. To learn more about your California privacy rights email firstname.lastname@example.org or visit shestepsforwardinternational.org
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding Company’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write to Company at the address below.
Note on the EU's General Data Protection Regulation
Company is located in the United States. Regardless of where you are located, we collect and use personal information as described above, including donor, website visitor, and other information, for the purposes described above. In particular, we receive personal information regarding donors located in the European Union from partner organizations located in the European Union when you make a donation through them and elect to share your information with us. Additionally, our website may be accessed and you may submit your personal information to us regardless of where you are located. We rely on either your consent or our legitimate interests as described above for the collection and use of such personal information. We retain personal information regarding donors for as long as necessary for our legitimate interests. If you have any questions or concerns, or would like to make any requests regarding your personal information, please contact us at firstname.lastname@example.org.
What choices do you have?
You may update at any time the information about you derived from information you have provided to Company. You may also ask Company at any time to remove your name from the list of Members who wish to receive electronic communications and e-mail advertisements from Company or its affiliates by simply sending such a request to Company at the addresses given below. Once you opt out, Company will honor your choice until you inform it otherwise. Please remember, however, that if Company has already shared information about you pursuant to your registration and participation in any special programs of its business affiliates (as described above), Company has no control over how such business affiliates may further use that information, and you will need to contact them directly in that regard.
Subject to applicable law, you also have the right to (i) restrict Company’s use of information that constitutes your personal data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe Company maintains your personal data within the scope of the General Data Protection Regulation (“GDPR”), you may direct your questions or complaints to Company or your local supervisory authority.
Your Legal Rights
You have the right to any of the following at any time:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data Company holds about you and to check that it is lawfully processing it.
Request correction of the personal data that Company holds about you. This enables you to have any incomplete or inaccurate data Company holds about you corrected, though it may need to verify the accuracy of the new data you provide to it.
Request erasure of your personal data. This enables you to ask Company to delete or remove personal data where there is no good reason for it continuing to process it. You also have the right to ask Company to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where Company may have processed your information unlawfully, or where Company is required to erase your personal data to comply with local law. Note, however, that Company may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, within a reasonable amount of time after your request.
Object to processing of your personal data where Company is relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where Company is processing your personal data for direct marketing purposes. In some cases, Company may demonstrate that it has compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask Company to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. Company will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for Company to use or where Company used the information to perform a contract with you.
Withdraw consent at any time where Company is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Company may not be able to provide certain products or services to you. Company will advise you if this is the case at the time you withdraw your consent.
Any request made by you will be processed within thirty (30) days of you providing notice to Company.
Questions or suggestions
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