PRIVACY AND INFORMATION SECURITY POLICY
EFFECTIVE DATE: SEPTEMBER 18, 2007
This Privacy and Information Security Policy ("Policy") covers information collected through www.seedsofcompassion.net. ("Site") and information relating to the subject matter of the Site. When the personally identifiable information (“PII”) identifies an individual and is subject to an applicable data protection or privacy law ("PII"), it is subject to the restrictions imposed on us by this Policy; otherwise, we may use the information (including non-PII) for any lawful purpose.
WHO WE ARE
We are Seeds of Compassion, ("we" or "us"), an initiative of the Kirlin Charitable Foundation working to promote social and emotional learning so that children succeed in school and life. If you have questions or concerns you may e-mail us at privacy@seedsofcompassion.org.
INFORMATION THAT WE COLLECT
We collect the information that you provide to us, such as your name and email address when you are requesting to be added to our mailing list or send us an email or letter.
You are in control of the personal information that you provide to us. You agree not to provide PII or confidential or sensitive information unless: (1) you have obtained any required permission to do so under applicable law and, (2) for PII, have informed the person whose data will be included that their PII will be subject to this Policy and you have obtained their consent to this Policy. By providing information to us, you represent and warrant that you have made all required disclosures and obtained all required permissions.
INFORMATION THAT WE COLLECT AUTOMATICALLY
We routinely learn certain information about visitors to the Site such as:
- the domain name and host from which you access the Internet and the Internet address of the Site from which you direct-linked to ours;
- the date and time you access the Site and pages you visit;
- your computer’s IP address and information about its operating system, and the Web browser you use; and
- information to combat fraud or misuse.
OUR USES OF INFORMATION
- What We Will Not Do: We will not sell or rent PII to a non-affiliated third party for their for-profit marketing purposes. We will not sell or rent PII with charitable or non-profit organizations for their promotional purposes, absent your consent to do so.
- What We May Do: In general, we use PII to process, respond to, communicate about, investigate and enforce our rights and materials you may submit. We tend to use non-PII for purposes such as measuring the number of visitors to sections of our Site, making our Site more useful to visitors, and other purposes.
Subject to applicable law, we reserve the right to do the above and the following worldwide: use, access (or bar access to), process, disclose, display, share, transfer, store, sell, retain, commingle, investigate, verify, prove and otherwise deal, voluntarily or as required by law, with (collectively "Disclose") all PII, non-PII and other information. We may Disclose the foregoing internally or to third parties or through any databases for any purpose not prohibited by law or, in our discretion, to help prevent or address perceived harm, damage or loss to us or others. Without limiting the foregoing we provide the following examples of what we may do. We may Disclose information, including PII:
- To respond to your requests and to respond (as legally required or voluntarily) to requests from or reports to governmental or similar authorities, other charitable organizations, credit reporting agencies and others who deal with or inquire about you;
- To and from any locations worldwide, such as locations of us or our agents, affiliates, service providers. This includes (but is not limited to) changes of control or operations or the like;
- To enforce, actual or potential transactions, requests, actions, applications, proposals, grants and rights;
- To enable performance by, or meet requirements of, third parties such as service providers, content providers, affiliates, agents, investigators, attorneys, researchers, consultants, auditors, lenders, publicists and others;
- To respond to legal process or to make Disclosures under programs intended to prevent or investigate persons or potential crimes. This includes but is not limited to checking any or all PII with the U.S. Treasury's Office of Foreign Assets Control. We reserve the right (but do not undertake an obligation) to notify you of legal process such as a subpoena or the like, if notification is lawful. If there is objection to our responding, the objecting person must seek a valid court order (from a court in the correct jurisdiction) allowing us to delay or forego responding and serve it on us at least three business days before we must respond;
- To promote our mission or other charitable purposes.
The above descriptions are not a list of all possible Disclosures we may make. This Policy is intended to aid your understanding of our general practices.
We generally will retain information for as long as required, allowed or we believe it useful, but do not undertake retention obligations. We may dispose of information in our discretion without notice, subject to applicable law. You must keep your own, separate records.
CHOICE
This Policy reflects what we believe is needed to effect our charitable mission. If you are not comfortable with the Disclosures we may make, please do not provide any information to us or otherwise use the Site.
We generally do not send "commercial e-mails" (e.g., e-mails whose primary purpose is to advertise a product or service); if we do, we will provide any "opt-out" choice required by applicable law. We reserve the right to communicate with you about any subject matter of the Terms or any other subject matter not prohibited by law.
ACCESS
Information relating to Seeds of Compassion is not necessarily maintained in a retrievable form. However, you may make changes, corrections or updates to some PII that we use for communications with you, by contacting privacy@seedsofcompassion.net. We may keep a record of all information that is changed (including deletions) and Disclose it for any lawful purpose. We may determine what may be changed (e.g., if we are required to keep track of certain kinds of transactions, you may not change relevant information).
SECURITY AND RELATED NOTICES
- Your e-mails to us are not necessarily secure against interception so do not include sensitive information in them—we generally will not ask for passwords or the like in an email and you should assume that if you get such a request, it might be fraudulent.
- You agree not to enter information on the Site if you (or anyone else whose information you enter) desire a higher level of security or if you have not obtained any appropriate consents.
- We believe that the security we have in place is appropriate to the subject matter of our Site, but WE DO NOT GUARANTEE SECURITY. Neither people nor security systems are foolproof, including encryption, and people can commit intentional crimes, make mistakes or fail to follow policies YOU ASSUME THE RISK OF ANY INADEQUACY OR FAILURE OF SECURITY AND AGREE TO DO WHAT YOU REASONABLY CAN TO PROMOTE SECURITY (such as by guarding your password if one is used). If applicable law imposes any non-disclaimable duty (if any), you agree that the standard used to measure our compliance with that duty will be one of intentional misconduct.
- Your Consent to Email Notice: If we are required to disclose or provide notice of invasion of certain security systems, we will do so when required by posting notice on our Site or, in our discretion, by giving it to any email address provided by you.
KEEPING UP TO DATE ON OUR PRIVACY POLICY CHANGES
We may amend this Policy at any time and will post any revised policy and effective date on the Site.
