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Privacy Policy

 

Last Updated: May 25, 2018

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The Sarafian Foundation is committed to respecting and protecting your privacy. Visitors may access the The Sarafian Foundation website while remaining anonymous and without revealing any personal information (except as referred to below under “Cookies”). Occasionally, and in order to provide relevant, desired information concerning services, The Sarafian Foundation may request personal information from you. As a website user or subscriber, you are always entitled to update your personal information if necessary or ask any questions about this Privacy Policy by contacting us at: 

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Phone: 1.916.684.8957 

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Email: ayo@thesarafianfoundation.org

 

This Privacy Policy (“Policy”) explains how your personal information is collected, used, and disclosed by The Sarafian Foundation when you access or use our website, located at www.thesarafianfoundation.org, or when you interact with us offline or on third party websites and/or platforms where we have an official presence.

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If you are visiting us from the European Union (EU) or European Economic Area (EEA), please be sure to read to section entitled "ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS” near the end of this Policy for information on how we comply with privacy laws applicable to you.

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Because The Sarafian Foundation is committed to protecting your privacy, The Sarafian Foundation will not sell, rent or otherwise disclose this information to any third party, except as described in this Policy. The Sarafian Foundation maintains all personal information as private to the best of the organization's ability. However, personal information may be disclosed under the limited circumstances described below, and by submitting your personal information, you agree that The Sarafian Foundation may do so. The Sarafian Foundation acquires many international website visitors, thus this Policy complies with various global regulations.

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To participate in certain activities and to obtain certain services offered on our website, you will be asked to provide varying amounts of personal information. You understand and agree that the personal information provided by you that is collected by us via our website may be held on computers in various jurisdictions around the world. In addition to the information you provide, The Sarafian Foundation may also collect information during your visit to The Sarafian Foundation's website through our automatic data collection tools, which may include Web beacons, Cookies, embedded Web links, and other commonly used information-gathering tools. These tools collect certain standard information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at The Sarafian Foundation website. They may also collect information about your Internet Protocol (IP) address, click-stream behavior (i.e. the pages you view, the links you click, and other actions you take in connection to The Sarafian Foundation website and social media accounts) and donation information. An IP address is a number that is assigned to your computer when you are using your browser on the Internet. The servers that operate the The Sarafian Foundation website automatically identify a computer by its IP address. The Sarafian Foundation may also use some of these automatic data collection tools in connection with certain emails sent from The Sarafian Foundation, and therefore may collect information using these tools when you open the email or click on a link contained in the email.

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Furthermore, we collect information about you in various ways. For example, we collect personal information you provide us when you sign up for our newsletter, make a donation, contact us, attend our events, apply for a scholarship, or communicate with us through third party sites (i.e., Twitter). Such information includes your name, email address, address, phone number, billing information and any other contact or demographic information you choose to provide.

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We do not share your personal information including your IP address with third parties other than as follows: when you give your consent to do so, including if you are notified that the information you provide will be shared in a particular manner, and you provide such information; with third party vendors, consultants and other service providers who are engaged by us and need access to such information to carry out their work; when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to (i) comply with laws or respond to lawful requests, legal process or legal authorities (ii) protect the rights, property or safety of The Sarafian Foundation and our employees, agents, donors and others, and (iii) respond to an emergency or protect the personal safety of any person; in an aggregated state or anonymized form that does not directly identify you, though it may indirectly; and in connection with, or during negotiations of, an acquisition, financing, merger or sale of all or a substantial portion of our assets. Additionally, if The Sarafian Foundation, in good faith, determines that you have used the service to menace, threaten, harass, intimidate or otherwise deceptively pose as another person, your actions will be investigated and your IP address may be disclosed to the recipient of any email, their legal counsel or representatives, and law enforcement officials as part of such an investigation.

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We automatically collect certain information using “Cookies.” Cookies are small data files stored on your hard drive by a website. Among other things, Cookies help us improve our website and your experience. We use Cookies to see which areas and features are popular and to count visits to our website. Most web browsers are set to accept Cookies by default. If you prefer, you can usually choose to set your browser to remove and/or reject Cookies. To view how to specifically opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/. Please note that if you choose to remove or reject Cookies, this could affect certain features of our website. We also may collect information using web beacons. Web beacons are electronic images that may be used on our website or in our emails. We may use web beacons to deliver Cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

 

We use personal information for the purposes described in this Policy or otherwise disclosed to you at the time of collection. We may use your information to: operate and improve our website; respond to your comments and questions and provide customer service; process your donations, deliver services that you request and send you related information, including confirmations, updates and support and administrative messages; communicate with you about upcoming events, new opportunities, progress or success of programs and other news about The Sarafian Foundation or selected partners that we think will be of interest to you; use your residential address to communicate via postal mail; and link or combine with personal information we get from third parties, such as Google Analytics, to help understand your needs and provide you with better service. We may store and process information in the United States and other countries.

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This website contains links to other websites. Please be aware that The Sarafian Foundation is not responsible for the privacy practices of other such websites. The Sarafian Foundation encourages users to be aware when they leave this website and to read the privacy statements of each website they visit that collects personal information. While The Sarafian Foundation carefully chooses the websites to link to, this Policy applies solely to information collected on The Sarafian Foundation's own website and social media accounts. 

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We take responsible and reasonable measures to help protect your information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. The Sarafian Foundation employs industry-standard security procedures and processes to safeguard the confidentiality of users’ personal information. The Sarafian Foundation, or agents and partners on behalf of The Sarafian Foundation, do everything in their reasonable control to protect your information. Furthermore, The Sarafian Foundation professionals who deal with user information are kept up to date on various security and privacy practice issues as they arise, and held to the utmost level of integrity. 

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The Sarafian Foundation does share non-personal, non-individual information from which individuals cannot be identified and which do not relate to individuals in aggregate form with third parties for business purposes, such as consultants to the organization. The Sarafian Foundation will not disclose personal information to any third parties without your consent except the very limited circumstances previously listed.

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You may opt-out of receiving emails from The Sarafian Foundation by following the instructions in those emails. If you opt-out, we may still send you non-promotional emails, such as emails about donations or our ongoing relations. You may request changes to your contact preferences and the personal information you have provided by calling (916) 684-8957 or emailing ayo@thesarafianfoundation.org. 

 

While the goal is to safeguard users’ and members’ personal information, The Sarafian Foundation cannot ensure or warrant the security of any transmission and your information is submitted at your own risk.

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By using www.thesarafianfoundation.org, or official social media accounts operated by The Sarafian Foundation, you signify your acceptance of this Policy, as amended from time to time in accordance with this paragraph. If you do not agree with the content of this Policy, please do not use this website. The Sarafian Foundation may revise this Policy from time-to-time and reserves the right to do so. If The Sarafian Foundation decides to change this Policy, the organization will post the new policy on the website. When we do so, we will revise the "Last Updated" date at the top of this Policy. As policies are subject to change at any time and without prior notice, The Sarafian Foundation encourages you to check the website whenever you might have questions or concerns. If at any point The Sarafian Foundation decides to use personally identifiable information in a manner different from that stated at the time it was collected, The Sarafian Foundation will notify users by way of an email to obtain their consent as a condition of doing so. You will still have the opportunity to elect not to have The Sarafian Foundation  use your information in this different manner. You may also request to know all information that The Sarafian Foundation has collected on you, and you may have this information removed from our data collection if you reside in legally applicable locations.

 

If the General Data Protection Regulation applies to you because you reside in the European Union, you have rights under data protection laws in relation to your personal data: 1) The right to be informed, which is our obligation to keep you informed on how The Sarafian Foundation uses your personal data; 2) The right of access, which is your right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold on you; 3) The right to rectification, which is the right to make us correct personal data about you that may be incomplete or inaccurate; 4) The right to erasure, which is also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it); 5) The right to restrict processing, which is the right for you in certain circumstances to ask us to suspend processing personal data; 6) The right to data portability, which is the right for you to ask us for a copy of your personal data in a common format; 7) The right to object, which is the right for you to object to us processing your personal data; and 8) Rights in relation to automated decision making and profiling, which is your right to have us be transparent about any profiling we do, or any automated decision making.

 

The Sarafian Foundation will not use your information other than in accordance with this Policy under which it was collected absent permission to do otherwise.

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The Sarafian Foundation welcomes your questions and comments regarding this Policy. Please contact us via the “Contact” tab on the home page of our website at this location: www.thesarafianfoundation.org.

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Additional information for European Union users are provided below: 

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ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS

References to “Personal Information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

The Sarafian Foundation is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at ayo@thesarafianfoundation.org. 

We will only collect, store, and process your personal information where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:


(1) You, the Data Subject, have given consent to the processing of your personal information for one or more specific purpose(s), for example by consenting to terms and conditions on our website, and consenting to the terms of this privacy policy;


(2) Processing is necessary for the performance of a contract to which you, the Data Subject, are party;


(3) Processing is necessary for compliance with a legal obligation to which The Sarafian Foundation as a Controller is subject;


(4) Processing is necessary for the purposes of the legitimate interests pursued by us as the Controller, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you, the Data Subject, which require protection of your personal information.

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we are required to keep basic information about our clients, contributors, and/or customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being clients, contributors, and/or customers for tax purposes. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

European data protection laws give you certain rights regarding your personal information as outlined previously in this Privacy Policy. You may ask us to take the following actions in relation to your personal information that we hold in order to carry out your primary right of being informed:

  • Opt-out: Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.

  • Access: Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct: Update or correct inaccuracies in your personal information.

  • Delete: Delete your personal information.

  • Transfer: Transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • Object: Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

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You can submit these requests by email to ayo@thesarafianfoundation.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described in our Privacy Policy or submit a complaint to the data protection regulator in your jurisdiction.

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.

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These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

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If you wish to exercise any of the rights set out above, please contact us via the "Contact" tab located on the home page of our website (see below). You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

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