Last modified July 2019
Please contact us at firstname.lastname@example.org, if:
- You would like to review, update, correct or delete personal information we have collected about you;
- If you would like to change any of your choices about personal information we collect about you; or,
- You would like to receive your personal data in a machine-readable format and send it to another controller.
YOUR CONSENT: OPTING OUT
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
INFORMATION WE COLLECT & HOW WE COLLECT IT
For the purposes of operating, improving, and monitoring the user experience on our Websites and our operations generally, we collect various information from those using the Websites. This information is broadly of two types: (1) Personal Information (information which is personal to you and can be used to identify you, such as your name, email address, an identification number, location data, an online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity) and (2) Website User Information (such as the number of users—but not their names—who have viewed an article or other resource or page on our Website.
Website User Information & Cookies/Web Beacons/TrackingWhen you access our Websites, we may collect Website User Information including, but not limited to, pages visited, hyperlinks used, type of device used, date, and time spent on our Websites.
Collecting such Website User Information may involve logging the IP address, operating system and browser software used by individual site visitors. From such information a user’s Internet Service Provider and other data could be inferred. We use this information to understand how to service users of our Websites and improve our Websites and programs by using Google Analytics or other website analysis tools.
We do not track visitors across third party websites to provide targeted advertising, and therefore do not respond to Do Not Track (DNT) signals.
What Personal Information Will Be Collected?
The Personal Information that we collect depends on the context of your interactions with us and the programs you attend, the parts of the Websites you access, the choices you make and the products and features you use. The Personal Information we collect may include the following:
Name and Contact Data. We may collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
All Personal Information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Examples of Interactions Which Might Result in the Collection of Personal InformationYou can access content on our Websites and use most features of our Websites without revealing any Personal Information. We only collect Personal Information when you provide it to us directly (or as noted in the Website User Information), for example:
- If you participate in our programs, activities, initiatives, and events;
- If you register with us to receive email newsletters or other communications from us;
- If you contact us through the Website;
- When you participate in surveys;
- When you submit testimonials;
- When you participate with social media accounts operated by INclude;
- When you provide User Content (as defined in the Terms and Conditions of Use) such as comments or written submissions on any part of the Websites that permit it; and
- When we need to verify your account information.
Collection of Personal Information by Third Party
Current Third Party Vendors:
- MailChimp – Email Newsletters: https://mailchimp.com/legal/privacy/
HOW WE USE PERSONAL INFORMATION WE COLLECT
We use Personal Information collected in the following ways:
- To indicate that you are the author of User Content (as defined in our Terms and Conditions of Use) if you submit such content with your name;
- To communicate with you periodically via email, if you have subscribed to one of our email lists;
- To facilitate your registration for an event or program;
- To communicate with you in connection with processing your grant application or employment application;
- To communicate with you about your account or any transactions with us;
- To respond to you when you contact us. We may also archive this information and/or use it for future communications with you.
- To contact you with service messages related to or affecting your use of our Websites, for example, to send you updates about changes in our terms or policies;
- To send you marketing messages, special offers, promotions, and other information about us and our programs and services, and other products or services that we think may be of interest to you (see opt-out procedures in “Your Choices and Communications Preferences” below);
- To investigate any activities that may violate our policies or be illegal;
- To manage and operate our organization in general.
- you have given us permission to do so;
- we need to perform a contract with you;
- the processing is in our legitimate interests and it’s not overridden by your rights;
- for payment processing purposes; or,
- to comply with the law.
DISCLOSURE OF PERSONAL INFORMATION
Consent: We may process your data when you have given us specific consent to use your personal information for a specific purpose.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Third Party Service Providers/Program Partners. We might share Personal Information with trusted third-party vendors to help us in operating our Websites, programs, and services. Specifically, these instances might include but are not limited to: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts .Also, if we work with a partner to help us to develop content and programs, we might share our email list and other information with them on a confidential basis.
User Content. Your name or username will appear next to any User Content you submit to us. If you post Personal Information in comments or other public forums on our Websites or on INclude Social Media, that information will be publicly available. If you are concerned about your privacy, we encourage you to use a username that is not personally identifiable and to refrain from posting Personal Information in comments or other public forums on our Websites or INclude Social Media. You may delete your Personal Information in comments or other forums but we are not able to recall information which you have made public prior to such deletion.
Aggregated Data. We may share information in an aggregated form or publish information based on aggregated data. However, we will only do so in a way that your personal identity is not ascertainable.
YOUR COMMUNICATIONS PREFERENCES
You can elect to opt-out of subscription and marketing communications from us via the unsubscribe mechanism provided within the communications that you receive from us. Even if you unsubscribe from general email communications, we reserve the right to notify you of changes or updates to the Websites and to communicate with you about your user account(s) or User Content you have submitted as necessary.
ACCESS, REVIEW, UPDATING, CORRECTING AND DELETING PERSONAL INFORMATION
You may review, edit or delete the Personal Information you have provided to us by contacting us at email@example.com. Please note, however, that even if you delete your information, there may still be residual information about you in our systems, for example in our log files. Also, please note that we may retain certain Personal Information in which we retain a legitimate interest not overridden by your interests or fundamental rights, to comply with our legal obligations, meet regulatory requirements, prevent fraud and abuse, or enforce our Terms and Conditions of Use. Upon request, we will also provide you with a copy of your personal data in a machine-ready format and send it to another data controller. You will need to provide sufficient identifying information, such as your name, email address and possibly additional information as a security precaution in order to do any of the foregoing.
We will retain your Personal Information for as long as your account is active or as needed to provide you with services. If you wish to cancel your account or request that we no longer use your Personal Information to provide you with services, please contact us at firstname.lastname@example.org. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, and enforce our policies and agreements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
It is your responsibility to maintain the confidentiality of your password(s).
You are also responsible for ensuring the accuracy of the Personal Information you submit to us. Submitting inaccurate information, or failing to maintain the accuracy of information that changes (for example, a change of email address) may disrupt your ability to receive email communications, may affect the information you receive from us, and may impact our ability to contact you/and or process your grant application. You can update your Personal Information at any time by logging into your relevant user accounts with us and our third party service providers. If you have any questions about updating your Personal Information, please contact us at email@example.com.
PROTECTING CHILDREN’S PRIVACY
We strongly believe in protecting the privacy of children. We do not knowingly collect or maintain any Personal Information on our Websites from persons under 13 years of age, and no part of our Websites are directed to persons under 13 years of age. Upon learning of the existence of Personal Information concerning persons less than 13 years of age that has been collected on our Websites without verified parental consent, we will take appropriate steps to delete it. If you become aware of any data we have collected from children under age 13, please contact us at firstname.lastname@example.org.
Note that we may store and process Personal Information on servers or on a cloud located in the United States or elsewhere. The data protection laws of the United States generally may not be as comprehensive or the same as those in the country where you are located. By using our Websites, you agree and consent that your Personal Information may be transferred to or stored in facilities in the United States or elsewhere.
Notwithstanding anything to the contrary set forth herein, European Union data subjects may seek an administrative or judicial remedy or to lodge a complaint with a supervisory authority, in particular in the member state of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. Information on how to file such a complaint is available here http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by emailing us at email@example.com.
If you are under 18 years of age, reside in California, and have a registered account with Websites, you have the right to request removal of unwanted data that you publicly post on the Websites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Websites, but please be aware that the data may not be completely or comprehensively removed from our systems.
QUESTIONS OR CONCERNS
If you have any trouble logging in, or have any privacy-related questions or unresolved problems, please contact us at firstname.lastname@example.org.
INclude-The Mental Health Initiative, Inc.
23 Waverly Place 5F
New York, New York 10003