Revised: July 26, 2018
What this privacy statement covers
Touch Foundation, Inc. (“Touch Foundation” or “we”) has a firm commitment to protecting your privacy. The following statement explains our privacy practices (“Statement”). This Statement is designed to provide you with the information you need to understand:
What information we collect about you;
- How we use the information that we collect;
- How we share that information with third parties;
- How we store and secure the information that we collect; and
- How to control your information.
This Statement is your guide to how Touch Foundation handles information that we collect about you when you access or use Touch Foundation’s Website (www.TouchFoundation.org) (“the Website”), donate to Touch Foundation, or otherwise interact with Touch Foundation through the Website (collectively referred to herein as the “Services”).
If you do not agree with this Statement, please do not access or use our Services or otherwise interact with Touch Foundation.
Who we are
Our Website: The Website is maintained by Touch Foundation, and we can be contacted as follows:
|Mailing Address:||Touch Foundation Inc.
P.O. Box 1420
New York, NY 10150
What information we collect about you
Touch Foundation collects information from you when (1) you voluntarily provide such information; and (2) when you use our Services, as further described below.
Information you provide to us:
The Website does not track, collect, or distribute personal information about visitors, except when such information is specifically and knowingly provided by you. Thus, we will only collect personally identifiable information, such as your name, address, email address, or telephone number or any other information that might reasonably be used to identify visitors personally (“Personally Identifiable Information”), when such information is provided to us in an email, on a form, when you sign up for an account with the Website, or in any other manner when this information is intentionally transmitted to Touch Foundation by you.
When you make a donation: When you make a donation, whether the gifts are made online or offline (i.e. in person, via mail or via phone), we collect Personally Identifiable Information including your name, address, telephone number, e-mail address and payment details, including credit card information or similar information.
When you join our mailing list or email us: When you join our mailing list, we collect Personally Identifying Information such as your name and e-mail address. You may decide to send us personal identifiers, for example, in an electronic mail message containing a question or comment, or by filling out a web form that provides us this information.
Information we collect automatically when you use the Services
Your use of the Website: We collect anonymous information for visitors to our Website. This can include the following: IP address, pages opened, date and time visited, and the type of browser used to the view the page. IP addresses are unique numeric identifiers that are assigned to each computer browser accessing the Internet. An IP address, by itself, cannot identify you personally. However, when combined with other information provided by your Internet Service Provider (ISP), your IP address can be used to identify the computer accessing the website. Under certain circumstances, recipients, their legal representatives, and/ or law enforcement authorities, may be able to combine this with information disclosed by ISPs to determine the source of a particular communication. The IP address that we collect is not recorded, but is used temporarily to determine domain type and in some cases the geographic region of the user. We do not make any type of association between this information and the identity of the donor or visitor.
The Website utilizes Google Analytics to analyze website traffic and usage and is an industry standard. Additional information about such analytics can be found at www.google.com/policies/privacy/partners/. To opt out of Google Analytics you can reach us at our address listed above.
How we use and share the information we collect
Our use of any such Personally Identifiable Information shall be in accordance with applicable laws, rules, and regulations. When you share information about yourself for a specific purpose, we will only use that information for that purpose.
Touch Foundation will never trade, share, or sell Personally Identifiable Information with or to anyone else except as needed to process the donations (as explained in more detail below) or as necessary to comply with the law, or any court order, to protect against misuse or unauthorized use of the website and/or any service offered therein or to protect the rights, property or safety of Touch Foundation’s interests or the interests of its donors (as explained in more detail below). Touch Foundation will never send donor mailings on behalf of other organizations.
In connection with your donation: If you make a donation in honor or memory of someone else, we will share your name with the acknowledgee if you request, but we will not share any personal information such as email, phone number, or physical address.
We recognize gifts made to Touch Foundation in our Annual Report and occasionally on our website, citing the donor’s name and identifying the general level of giving (no email, phone, or address information), unless you request otherwise, in which case you will be listed as ‘Anonymous’.
To process a payment: When you provide information in connection with a purchase or a donation, we use the personal information you provide in order to complete the transaction, including sharing information with third parties.
Our payment processing vendor, Blackbaud, processes online donations on our behalf. Blackbaud encrypts personal and credit card information during all transactions and sends an automated confirmation email for all completed transactions. Blackbaud has validated compliance with the Payment Card Industry Data Security Standard (PCI DSS) and the Payment Application Data Security Standard (PA-DSS). Please see Blackbaud’s Compliance Validation Certificate for detailed information.
All online transactions are processed on a secure (https) server and information entered on the donation page is encrypted using SSL (Secure Socket Layer) before transmission. Once donations reach our database through The Raiser’s Edge (a cloud-based CRM database), credit card numbers are encrypted, and only designated employees have access to your personal information (i.e., address, phone number, email address, etc.)
If you have any questions regarding the security of your credit card donation online, please e-mail Touch_Foundation@external.McKinsey.com, or call 212-351-0721.
To maintain our Website and resources: We may use Personal Identifiable Information in connection with facilitation of the operation of our Website (e.g., without limitation, maintenance services, database management, web analytics) or to assist us in analyzing how our Website is used, which may require us to share information with third parties. These third parties may have access to your Personally Identifiable Information; if they do, this access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose. We use anonymized information related to user demographics and behavior on our Website, e.g. to improve and tailor our content to our user’s interests, estimate our visibility to external audiences, and also to identify any potential breakdowns in the user experience (i.e. high bounce rate on certain pages).
To assist with fundraising: We may use third parties to assist with our fundraising efforts, such as Givergy, a digital fundraising platform, including, for example, collecting pledges during a fundraising event. These third parties may have access to your Personally Identifiable Information. Their access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose.
To communicate with you about the Services: We use personal identifiers from email to respond to your requests. We may forward your email to other employees or members of our organization or consultants who are better equipped to answer your questions. We may also use your email or mailing address to contact you in the future about our programs that may be of interest. If you sign up to join our email list, we will only send you the information you have requested or anything.
How we store and secure information we collect
Unfortunately, data transmission over the Internet cannot be guaranteed to be secure nor is any security system completely secure. Although we do our best to protect your personal information, we do not guarantee the security of any information you transmit to us or provide online. It is possible that unauthorized “hackers” may post or transmit offensive or obscene materials on our website and that you may be involuntarily exposed to such materials. It may also be possible for other users or “hackers” to improperly gain access to or obtain personal information about you. By using the website, you assume the risk of such occurrences. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.
How long we keep information:
We keep Personally Identifiable Information permanently, unless you request that it is removed. However, we do not save, nor otherwise retain credit card numbers, beyond the last 4 digits.
How to control your information
If you ever change your mind about receiving any form of communication from us, you can always contact us directly at the email address or mail address provided above to request removal from our mailing list.
If you would like to make corrections to your information or verify that we have received your information, please contact us directly at the email address or mail address provided above.
Additional EU Disclosures
Our role as data controller: If you are located in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the “Who We Are” section above. If you are situated in the EU and have a complaint, please contact us at Touch_Foundation@external.McKinsey.com.
Legal bases for processing: If you are an individual located in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation (“GDPR”). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
We will only use your Personally Identifiable Information for the purposes for which we collect it. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using certain of the Services.
Rights of EU Data Subjects: Under certain circumstances, you have rights under data protection laws in relation to your Personally Identifiable Information. You have the right to:
- Request access to your Personally Identifiable Information (commonly known as a “data subject access request”). This enables you to receive a copy of Personally Identifiable Information we hold about you and to check that we are lawfully processing it.
- Request correction of Personally Identifiable Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personally Identifiable Information. This enables you to ask us to delete or remove Personally Identifiable Information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personally Identifiable Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personally Identifiable Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will inform you as above, if applicable, at the time of your request.
- Object to processing of your Personally Identifiable Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which 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 we are processing your Personally Identifiable Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your Personally Identifiable Information. This enables you to ask us to suspend the processing of your Personally Identifiable Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your Personally Identifiable Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personally Identifiable Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your Personally Identifiable Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
To exercise your rights, please contact us at Touch_Foundation@external.McKinsey.com.
Our Website contains links to other websites. It is important to remember that when you click on one of these websites, you are entering a different website. As we are only responsible for our own Website, we strongly encourage you to visit the privacy policies of these websites.
Children Under 16
This website is not directed at children 16 years of age or younger. We, therefore, shall not intentionally collect information about any user under the age of 16. If you are under 16, do not use or provide any information about yourself to us, including your name, address, telephone number or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental/guardian consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Touch_Foundation@external.McKinsey.com.
In certain circumstances, we may share information when we believe it is necessary to comply with the law, or any court order, to protect against misuse or unauthorized use of the website and/or any service offered therein or to protect the rights, property or safety of our interests or the interests or our donors and you hereby agree to such disclosure. This may include sharing information with other companies, lawyers or government agencies in connection with fraud protection and credit risk reduction or investigating reports of users using a false email address or users sending or posting harassing, threatening, or abusive messages or other issues related to fraud or government subpoenas, warrants and/or court orders.
California Privacy Rights
California Civil Code Section § 1798.83 permits California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Touch_Foundation@external.McKinsey.com.
Our Do Not Track Policy
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals, but we do provide you the option to opt out of interest-based advertising. To learn more about IBA or to opt-out of this type of advertising, visit the Network Advertising Initiative website http://www.networkadvertising.org/choices and the Digital Advertising Alliance website http://www.aboutads.info/choices. Options you select are browser- and device-specific.
For More Information:
If you have any questions or concerns regarding your privacy, please e-mail Touch-Foundation@external.McKinsey.com, or call 212-351-0721 for more information.